Privacy policy profile for EuroBonus members

Summary

• Our aim and vision for the EuroBonus program

  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. 
  

  Membership in the EuroBonus program therefore requires us to process your personal data. This Privacy Policy for EuroBonus Members is an integral part of the EuroBonus Terms and Conditions.
  

  Should you not wish to become a EuroBonus member or want to terminate your membership, you are welcome to use the SAS’ website or the SAS mobile app to book flight tickets etc. as a regular visitor or using a Profile Account. Please see SAS’ Profile Account terms and conditions and SAS’ Privacy Policy for Profile Account holders.

• Joint controllers

  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.
  

• Full transparency

  EB and SAS as joint controllers (hereafter “we” or “us”) are committed to ensuring your right to privacy and will only process your personal data as described in this Privacy Policy for EuroBonus members. 

  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 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.  

• 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.

• Legitimate interests

  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 EB’s and SAS’ business partners (“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.
  • If you accept our and SAS' cookies (see SAS’ Cookie Policy), data on your online behavior as registered by e.g. cookies, Adobe Analytics and Google Analytics on our ans SAS' website or SAS'´application, e.g. on what terms you search for, length of visit, which destinations are of interest to you and which links/headlines you click on. Using member IDs, we can track and address members with suggestions and advertising across different units such as the members’ mobile device and computer, or help you memorise your latest search.
  • Information on customer care and travel irregularities such as delayed or canceled 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 SAS’ applications and EB’s/SAS’ websites are well-used and which ones are not, and use this data to continuously improve and facilitate your use of EB’s and SAS’ platforms and services.
  • Allow SAS’ 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 SAS’ lounge is of interest to you to optimise 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 EB’s and SAS’ ability to give better personalised service at EB’s and SAS’ customer care departments. For instance, data on recent flight irregularities that you have experienced allows EB and SAS 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:

  Provided that you consent to the use of cookies on EB’s and SAS’ websites or SAS’ applications, we will also process your personal data in order to:

  • Collect, store and study online behaviour alone or pooled with other personal data from SAS’ customer database, in order to identify e.g. destinations, you may be interested in. We enrich SAS’ customer database with this data from e.g. cookies and Google Analytics. Vice versa, we enrich the online data with SAS’ 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 SAS’ website and application as well as on external media channels such as Facebook and Google.

  Please read more about our and SAS’ use of cookies in SAS’ Cookie Policy.

• 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 EB 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 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.

  • EB’s and SAS’ 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.
• 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.

  Since travels and hotel visits typically vary between seasons and are not everyday purchases for most leisure travelers, we need to store our members’ personal data in order for our analyses of your needs and preferences – and our decisions on offers and services – to be meaningful. Personal data regarding travel, hotel and car rental purchases and other purchases will therefore be processed for the purposes set out in this Privacy Policy for EuroBonus members for three years from the date it was first collected or subsequently updated.

  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 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.

  Where there is no adequacy decision by the European Commission and also no established appropriate safeguards in the form of standard contractual clauses as outlined above, we will transfer your personal data to affiliates within the SAS group and to our business partners on the legal basis of the EuroBonus Terms and Conditions, including the present Privacy Policy for EuroBonus members. More specifically, we will transfer your personal data on the basis that the transfer is necessary for us to perform the EuroBonus Terms and Conditions, or to conclude or perform a contract concluded in your interest between us and another business partner.

• How do I decline to receive direct marketing?

  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.

• Who can I talk to about my personal data and my rights?

  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: dataprotectionofficer@sas.se. If you have questions regarding the EuroBonus program in general, please contact SAS Customer Service / EuroBonus at www.flysas.com.

• What are my rights?

  We want to be as transparent and clear as we can on how we process your personal data, and have therefore taken particular care in illustrating your rights under this Privacy Policy for EuroBonus members. On your EuroBonus account, you can now not only view and update your contact details and EuroBonus points, but also find information on your rights and on our processing of personal data laid out interactively. By navigating and operating the EuroBonus account, you can also easily enforce your 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:

  • 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).

  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 dataprotectionofficer@sas.se.

  Please note that restricting the processing of your personal data or enforcing your right to be forgotten will mean that we will no longer be able to provide you with our services under the EuroBonus program. The processing of personal data as set out in this Privacy Policy for EuroBonus members is part of the EuroBonus Terms and Conditions and is necessary for us to provide you with personalized services offered to EuroBonus members.

  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 EB or 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:

  • 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.

  This Privacy Policy for EuroBonus members was last updated on 31 October 2020.