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Effective: 31 October, 2020
As a member of the EuroBonus program, we invite you to be part of the EuroBonus community and experience an array of easy, joyful and personalised 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.
Airstair 3 AB, with corporate identity number 559224-9782, under change of name to SAS EuroBonus AB (“EB”), and 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 (“SAS”), will jointly determine the purposes and means of the processing of your personal data as so called joint controllers within the meaning of Article 26 of the General Data Protection Regulation (EU Regulation no. 2016/679). For this purpose, EB and SAS have entered into a joint-controller agreement.
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.
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.
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 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 fulfil 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 EB 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 fulfil 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.
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.
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 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:
Improving our products, services, features and communication:
Getting to know you and personalizing our communications, service and offers:
Cookies and online behavior:
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 EB to perform the EuroBonus Terms and Conditions.
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 SAS’ application or EB’s/SAS’ 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.
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.
Personal data is shared between affiliates within the SAS group to manage and operate SAS’ 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 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.
EB may use post, landline or mobile phone, SMS, email, social media and other digital channels to communicate direct marketing with you. EB may use these means of communication to send promotional communications to you concerning EB’s, SAS’ and our business partners’ respective products and services. EB 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 EB by using the links in the relevant digital communication or by changing the settings in your EuroBonus account.
As set out above EB and SAS are so called joint controllers of your personal data, and are the legal entities responsible for personal data in accordance with applicable legislation on data protection, including the GDPR.
SAS has designated a Data Protection Officer who supports SAS in ensuring that personal data is processed correctly. SAS’ Data Protection Officer is also the Data Protection Officer for EB and supports EB in ensuring that 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 Customer Service / EuroBonus at www.flysas.com.
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 the 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.
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: