Data Privacy Statement
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our social media profile (hereinafter referred to collectively as “online offer”). With regard to the terms used, such as “processing” or “responsible party”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Association Luxembourgeoise des Pilotes de Ligne a.s.b.l.
1A rue de Trèves
L-2632 Findel, Luxembourg
Types of data processed
– Stock data (for example, names, addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as “users”).
Purpose of the processing
– provision of the online offer, its functions and contents.
– answering of contact requests and communication with users.
– security measures.
– reach measuring/marketing
“Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an on-line identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
“Pseudonymisation” shall mean the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the use of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organisational measures ensuring that the personal data is not related to an identified or identifiable natural person.
“Profiling” shall mean any automated processing of personal data consisting in using such personal data to evaluate certain personal aspects relating to a natural person, in particular in order to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location of that natural person.
“Controller” shall mean the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
“Processor” shall mean any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 lit. d GDPR serves as the legal basis.
In accordance with Art. 32 GDPR and 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 varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to data, as well as access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 GDPR).
Cooperation with contract processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b GDPR for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called “contract processing agreement”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer data to a third country if the special requirements of Art. 44 ff. GDPR. In other words, processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to request confirmation as to whether or not data in question is being processed and to obtain information about this data and to receive further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
Under Art. 17 GDPR, you have the right to demand that data concerning you be deleted immediately, or alternatively, under Art. 18 GDPR, to demand that the processing of the data be restricted.
You have the right to request that the data concerning you which you have made available to us be received in accordance with Art. 20 GDPR and to demand that it be passed on to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
Right of withdrawal
You have the right to revoke consents granted in accordance with Art. 7 Para. 3 GDPR with effect for the future.
Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for the purposes of direct advertising.
Cookies and right of objection for direct mail
“Cookies” are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the cookies of this person, they are called “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 GDPR. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
Provision of our services
We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 para. 1 lit. b. GDPR, insofar as we offer contractual services to them or act within the framework of existing business relationships, e.g. to members, or are ourselves recipients of services and benefits. Otherwise, we process the data of data subjects in accordance with Art. 6 Paragraph 1 lit. f. GDPR on the basis of our legitimate interests, e.g. if it concerns administrative tasks or public relations work.
The data processed, the type, scope and purpose of such processing and the necessity of processing them are determined by the underlying contractual relationship. This basically includes inventory and master data of the persons (e.g., name, address, etc.), as well as contact data (e.g., e-mail address, telephone, etc.), contractual data (e.g., services used, contents and information provided, names of contact persons) and, if we offer services or products subject to payment, payment data (e.g., bank details, payment history, etc.).
We delete data that is no longer required for the provision of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of business processing, we retain the data for as long as they may be relevant to the business transaction and also with regard to any warranty or liability obligations. The necessity of storing the data is reviewed every three years; otherwise the statutory storage obligations apply.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) GDPR. The user’s details may be stored in a relationship management system (“RM system”) or comparable enquiry organisation. We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Newsletter and Press Releases – Mailchimp
The newsletters and press releases are sent via the mailing service provider “MailChimp”, a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the data protection regulations of the mailing service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The mail order service provider is used on the basis of our legitimate interests according to art. 6 para. 1 lit. f GDPR and an order processing contract according to art. 28 para. 3 sentence 1 GDPR.
The mail-order service provider may use the recipient’s data in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of the dispatch and presentation of the newsletters or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter or press release recipients to write to them itself or to pass the data on to third parties.
Hosting and e-mailing
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online offer.
For this purpose, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing agreement).
Collection of access data and log files
We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. GDPR data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidential purposes is excluded from deletion until final clarification of the respective incident.
Jetpack (WordPress Stats)
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) the plugin Jetpack (here the sub-function “WordPress Stats”), which integrates a tool for the statistical evaluation of visitor accesses and by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
Social media online presence
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Integration of third-party services and content
Within our online offer, we set the following priorities on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of such content are aware of the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required to display this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information on the browser and operating system, referring web pages, visiting time and other details on the use of our online offer, as well as being linked to such information from other sources.
Use of Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The Plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on blue tile, the terms “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook Social Plugins can be viewed here:
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law
If a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the users according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example, by pressing the Like button or posting a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymised IP address is stored.
The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and settings to protect the privacy of users, can be found in the Facebook data protection information:
If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it with his/her membership data stored on Facebook, he/she must log out of Facebook before using our online offer and delete his/her cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.