8 March 2018
Our aim and vision for the EuroBonus program
As a member of the EuroBonus program, we invite you to be part of our community and experience an array of easy, joyful and personalized services to help simplify your life. Our goal is to get to know you, so that we can provide you with tailored offers and services that are truly useful to you, and to filter away those that would only take up space and time.
We will below explain how we collect, use, transfer, store or otherwise process any personal data relating to you as a member of our EuroBonus program. Our aim is to be as clear, transparent and candid as possible. However, do not hesitate to contact us should you still have any questions about how we process your personal data.
What is personal data?
Personal data means any information relating to you as a natural person and through which you can be identified, directly or indirectly, such as your name or photo.
We recognize that special categories of information, such as data revealing ethnic origin, religious beliefs or health information, are particularly sensitive. We will only collect and use such sensitive data where strictly necessary. For instance, it is important for us to know if you are late stage pregnant or require a wheelchair to board a flight.
What does processing mean?
Processing of personal data means any operation or set of operations performed on personal data, whether or not by automated means. All actions carried out on personal data, from collection and storage to alteration, use or disclosure thus constitute ‘processing’.
The legal bases of processing member data
The EuroBonus Terms and Conditions
The foundation and purpose of the EuroBonus program is for you to earn points and benefits on your activities with us and for us to provide you with a spectrum of easy, useful and personally adapted services and offers. We are committed to getting to know you so that we can deliver the best individualised travel and life style deals and features that we can, and to continuously improve our EuroBonus program.
To be able to fulfill this promise, it is necessary for us to process data that relates to you as a person. The legal basis on which we process your personal data is thus the EuroBonus Terms and Conditions that govern the relationship between SAS and you as a EuroBonus member. We have below listed the different types of personal data that we will or may process in order to fulfill our requirements under the EuroBonus Terms and Conditions. In other words, we will only process the data necessary to meet our end of the EuroBonus Terms and Conditions.
You are, of course, free to terminate the EuroBonus membership at any time. You may also restrict the processing of your personal data, or ask us to correct or erase certain data. We will restrict the processing of your personal data, update or delete the personal data accordingly. However, please note that restricting the processing of personal data or erasing personal data entails a termination of the EuroBonus membership, as we will then no longer be able to provide you with our services of the EuroBonus program. For further information, please refer to your rights below.
Our legal obligations
We will process your personal data when we are under a legal obligation to do so, for instance when we are obliged to provide information to government authorities or we are subject to a court order.
We will process personal data based on our legitimate interests in order to prevent, investigate or report cases of fraud or safety issues and to cooperate with law enforcement agencies.
What personal data will we process?
In order to be able to provide you with the EuroBonus membership as promised, we collect and process the following data on you. We only collect the data we need to deliver on our promise for the EuroBonus membership.
- The information submitted when you apply for a EuroBonus membership and/or update your EuroBonus account, e.g. name, gender, birthday, address, country of residence and membership level.
- The details regarding your travels, e.g. the origin and destination of the trip, carrier, type of tickets, lounge visits, checked-in luggage, purchase of extra luggage, pre-ordered meals, flight seats or upgrades, duration of stay, time of purchase and amounts paid.
- The details collected by our business partners regarding your purchases, flight transfers, hotel and/or car rental purchases. For instance, the destination of the trip, duration of stay, name and location of the hotel, type of room, car rented, rental time, time of purchase and amounts paid.
- Data on other purchases or activities entitling you to earn or use EuroBonus points at our business partners’ physical or online stores, such as items purchased, the time of purchase and amounts paid.
- Demographic data obtained from our business partners, including data on home ownership, members of household and vehicle ownership.
- Publicly available data obtained from external sources, such as information on government authority registers, tax returns, LinkedIn, and news articles.
- Information on customer care and travel irregularities such as delayed or cancelled flights, lost luggage, and complaints, refunds, and compensation paid.
- Personal data created by us as a result of our analysis of the above data, such as customer segments, scorings and profiles established for you in order to e.g. adapt our communication, evaluate your price and product preferences or to predict what accessory services you may be interested in.
For what purposes do we use the data?
The fundamental aim of our EuroBonus program is to get to know our members so that we can offer you the best possible assortment of useful and personal travel and life style services and offers. To deliver on this promise, it is necessary for us to process the personal data on you as described in the section above.
Specifically, we will process your personal data for the following purposes:
Your membership account, bookings and travels:
- Administer your EuroBonus membership, points earned and used as well as update your contact details and cancel EuroBonus accounts of deceased members.
- Manage and carry out your bookings, purchases, discounts and flights. If you have chosen to receive emails from us, we will also send you a summary of relevant travel information, e.g. flight schedule and luggage included, prior to your departure. This summary will also provide you with relevant offers and benefits related to your upcoming travel, e.g. regarding lounge access or luggage.
Improving our products, services, features and communication:
- Process, on an aggregated level, all reservations and total revenue in order to optimize e.g. the flight network and pricing.
- Analyse how you collect and use your EuroBonus points, and what products and services you decide to purchase and how, so as to create more tailored and relevant offers for and activities alone or together with our business partners.
- Calculate the annual revenue from each EuroBonus member in order to reward loyal customers. Based on their life style and preferences, also organise and send out invitations to exclusive events and activities.
- Streamline our communication with you and minimise spam e.g. by registering if you do not open our emails, analysing what subjects are of interest and administering requests to no longer receive such emails. We also use the data to remove unnecessary information, e.g. offers for purchasing extra luggage if you have already done so.
- Identify our members in the entire travel chain and offer relevant travel benefits and information services. Based on your flight schedule information, we may for instance provide you with information on local train departures from the destination airport.
- Investigate what features and services of our application and website are well-used and which ones are not, and use this data to continuously improve and facilitate your use of our platforms and services. If you e.g. almost always use our application, we may offer you to no longer receive emails from us, but only application messages.
- Allow our flight crew, ground operations, customer service and other relevant SAS personnel to identify your membership level in order to provide you with associated benefits on-board and on-ground. We want to e.g. reward loyal members by directing/ automatizing the seat selection process towards your preferred seat.
- Analyse to what extent our members of different membership levels actually make use of their associated benefits. For instance, understand when and under which circumstances our lounge is of interest to you to optimize our members’ lounge visits.
Getting to know you and personalizing our communications, service and offers:
- Compile statistical data on needs, preferences, purchase behavior and purchasing power in the purchase of our and our business partners’ products and services, and analyse and apply this data to streamline and personalize the offers and services we provide to our members on an individual level.
- Create value in the EuroBonus program and understand your preferences, needs and (online) behavior and profile you as a basis for creating personalized offers and services. By using predictive models and scorings, we try to understand which members tend to appreciate what products and services and to thereafter highlight relevant products and services to those members.
- Examine and generalize needs, preferences, purchasing behavior and purchasing power to understand customers behavior and segments. For instance, we analyse what other customers tend to buy depending on different attributes (e.g. when they booked their trip, where they are going, how long they are away) and try to predict which products or services you may be interested in purchasing based on other customers’ behavior. These models and analyses are sometimes performed on our behalf by service providers contracted by us.
- Improve our ability to give better personalized service at our customer care department. For instance, data on recent flight irregularities that you have experienced allows us to anticipate what your phone call to customer care may be about and find a solution or award compensation.
- Follow up on paid media campaigns, such as information on impressions, clicks and conversion rates, to analyse and create platforms for communication. We monitor our campaigns both on an aggregated and on an individual level (provided that cookies are accepted) and obtain personal data from a range of sources, e.g. Facebook and Google.
Cookies and online behavior:
- Collect, store and study online behavior alone or pooled with other personal data from our customer database, in order to identify e.g. destinations, you may be interested in. We enrich our customer database with this data from e.g. cookies and Google Analytics. Vice versa, we enrich our online data with our customer database information. We use this data to e.g. provide you with targeted offers regarding that destination by placing banners and other advertisements on our own website and application as well as on external media channels such as Facebook and Google.
- Our different departments and sales points at airlines, such as information on lounge visits and customer care contacts.
- Our business partners, e.g. data on hotel reservations and rental car bookings from travel agencies, and data on purchases to collect or use EuroBonus points.
- Cookies that you accept and programs such as Google Analytics, Google Customer Match, Facebook Custom Audience, Adobe Analytics e.g. track and collect data on your online behavior.
- We create ‘new’ personal data based on the data collected from the sources above, in the form of predictive scorings and profiles/segments. These models and analyses are sometimes performed on our behalf by service providers contracted by us. For example we use a customer segmentation called Mosaic.
- Publicly available data from external sources such as public registers at government authorities, filed tax returns, LinkedIn and news articles.
- Correct, update or delete information that is incorrect or incomplete on your EuroBonus account.
- Restrict our processing of your personal data.
- To be forgotten. The right to be forgotten means that you may request that we delete all the personal data we have collected on you. Enforcing this right will normally entail termination of your membership.
- Receive a copy of the personal data related to you and information regarding our processing of your personal data in a commonly used data format and to transmit – or have transmitted, where technically feasible – the personal data to another controller.
- Request that personal data not be used for direct marketing purposes.
- Submit a complaint to the data protection authority within your jurisdiction, which in Sweden is the Data Protection Board (Sw. Datainspektionen).
- Collect and use your geolocation data, in order to provide you with real-time offers e.g. at restaurants and shops nearby a gate where you are located.
- Allow our business partners to use the personal data that they receive from us for their own purposes, to enable them to create targeted marketing via their own channels.
- Compile reports on travel patterns, spending etc. to sell to third parties.
- Purchase data from external sources, such as financial transactions based on EU Directive no. 2015/2366 (Payment Services Directive 2) for e.g. income and price sensitivity analyses.
- Pre-complete booking forms with your contact details, accompanying persons, passport and payment data etc. to facilitate a faster and simpler use of our services.
What is profiling?
Profiling means any form of automated processing of personal data in order to evaluate, analyse or predict aspects concerning someone’s personal preferences, interests, behavior, location or movements. In simpler terms, it is the analysis we carry out on your personal data to better understand what types of products, services, communication channels and features you appreciate and which ones you don’t. The fulfillment of many of our purposes above require different degrees of profiling, from placing members into different segments to creating more in-depth predictive scorings for certain behaviors and preferences.
Automated decision-making is when the results of profiling lead to a decision based only on automated processing which produces a legal effect for you or affects you in a similar fashion. For example, our analysis of our members’ different membership levels, purchasing power and preferred travel class may result in differentiated offers, in terms of price and level of comfort, being sent to those members with respect to not only flights, but also to hotels or rental cars.
The logic behind such processing is thus to use available technologies not only to analyse needs and preferences, but to also produce different effects based on those needs and preferences. Where these effects carry legal weight or are otherwise significant for you as a member, the processing may constitute automated decision-making and will only occur subject to your consent, unless the processing is necessary in order for us to perform the EuroBonus Terms and Conditions.
Where do we get your personal data from?
The personal data is collected from many different sources.
Most of the personal data we hold on you will stem from you directly, e.g. from your setting up a EuroBonus account or purchase of flights and activities through our application or website. Similarly, we obtain information from you when you decide to use your EuroBonus card or your points, or when you decide to use other offers and services.
In addition, we obtain personal data from you from the following sources.
How long will we keep your personal data?
We only keep personal data for the period of time necessary to meet our commitments under these EuroBonus Terms and Conditions.
If you have accepted cookies, personal data collected through Google Analytics will be stored for three years. Personal data collected through Adobe Analytics will be stored for two years. Having historical data helps us better understand your behavior and interactions with us, and a three year data period is required to obtain a sufficiently good data foundation for statistical analysis. Using the data for analytical predictive and personalisation purposes therefore helps us adapt our products and services to your needs.
Who may access your personal data?
Personal data is shared between affiliates within the SAS group to manage and operate our international flights, the EuroBonus points system, the EuroBonus account and member information from EuroBonus members internationally.
Personal data is also shared with our business partners in order to coordinate special offers and activities. For example, we cooperate and exchange personal data with travel agencies to analyse your behavior and preferences regarding, among other things, hotels and rental cars, in order to be able to provide you with relevant hotel and rental car offers.
We also pool personal data collected by us with personal data obtained from our business partners and external sources.
Personal data that is shared within the SAS group or with our business partners will sometimes be transferred to countries that do not belong to the European Union (“EU”) or the European Economic Area (“EEA”) and which do not ensure an adequate level of protection for personal data. Such transfers will be carried out in compliance with applicable data protection laws.
When transferring personal data to a non-EU/EEA country without an adequate level of protection for personal data we will apply appropriate safeguards normally by entering into standard contractual clauses adopted by the European Commission. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
How do I decline to receive direct marketing?
By enrolling in the EuroBonus program, you consent to receive direct marketing from us. We and our business partners may use post, landline or mobile phone, SMS, email, social media and other digital channels to communicate with you. We may use these means of communication to send promotional communications to you concerning our respective products and services. We will only communicate with members below the age of 18 years to confirm the services/offers used. Any other direct communication with members under the age of 18 years will take place only by post and will be addressed directly to the legal guardian.
You may at any time decline to receive marketing from us and our business partners by using the links in the relevant digital communication or by changing the settings in your EuroBonus account.
Who can I talk to about my personal data and my rights?
Scandinavian Airlines System Denmark-Norway-Sweden, a consortium established under the laws of Denmark, Norway and Sweden, and having its principle office at Frösundaviks allé 1, SE-195 87 Stockholm, Sweden, is the controller which, alone or jointly with others, will determine the purposes and means of the processing of your personal data.
SAS is the legal entity responsible for personal data in accordance with applicable legislation on data protection, including the General Data Protection Regulation (EU Regulation no. 2016/679).
SAS has designated a Data Protection Officer who supports SAS in ensuring that the members’ personal data is processed correctly. You may contact the Data Protection Officer with questions or requests relating to the processing of your personal data, at the following address: firstname.lastname@example.org. If you have questions regarding the EuroBonus program in general, please contact SAS Sales & Service / EuroBonus at www.flysas.com.
What are my rights?
For instance, you have the right to access the personal data that we process on you. You can easily obtain an excerpt of the personal data on you that we process and find more information by signing in to your EuroBonus account.
In the same way, you can find further information on and enforce also the following rights:
You can also find more information about all the different safeguards and technical measures we have put in place to protect your data and your right to privacy and freedom and to ensure that we are fully compliant with applicable data protection legislation.
If you require assistance or have any questions regarding your rights, please contact our Data Protection Officer at email@example.com.
Should you not or no longer wish to be a part of our EuroBonus system, you are free to terminate the EuroBonus program at any time, as set out in Section 6.6 of the EuroBonus Terms and Conditions.
When may SAS ask me for my consent?
In certain situations, we will need your consent in order to process your personal data.
The collection, analysis and transfer of personal data described below may in many ways further enhance your EuroBonus membership experience. However, we will only process your personal data for these purposes following your consent.
For instance, we may request your consent in order to: