Data Protection notice and declaration of consent

The controller for the processing of personal data under the General Data Protection Regulation (GDPR)

Deutsche Lufthansa Aktiengesellschaft
Venloer Strasse 151-153
50672 Cologne
Germany

Tel.: +49 (0)69 86 799 799
Website: Help and Contact

Microsoft Ireland Operations Limited
Atrium Building Block B
Carmenhall Road
Sandyford Industrial Estate
Dublin 18
Ireland

Lufthansa Global Tele Sales GmbH
Ullsteinstr. 118
Haus 1A
12109 Berlin
Germany

Mindpearl Ltd.
Caribbean Plaza, 2nd Floor, North Building
878 West Bay Road
Grand Cayman
KY1-1003
Cayman Islands

Genesys Telecommunications Lab. GmbH
Joseph-Wild-Strasse 20
81829 Munich
Germany

Cognigy GmbH
Speditionsstrasse 1, Sign Building
40221 Dusseldorf
Germany

Customers and interested third parties can initiate a dialogue with the Lufthansa chat assistant via the website ​lh.com/bot, or with their own Facebook account on ​lh.com/bots, and the messenger feature of Facebook there or integrated or linked on the regular Facebook pages of Lufthansa, to obtain information about flights and other products, services and topics of Deutsche Lufthansa (“chat function”).

A chat assistant, also known as a chatbot, is a computer program that interprets written text and automatically responds to written enquiries. In addition to the chat function, users can register for the latest news about their flight status and other operational messages. Messages about flight operations are also sent via Facebook Messenger.

In addition to the chat function, customers can also obtain information and services from Deutsche Lufthansa via the Service Centre or the company’s website. You will find further information about these options under ​Help and Contact.

Deutsche Lufthansa only uses the personal data you provide via the chat assistant as is necessary for the use of the chat assistant via Facebook Messenger or on lufthansa.com. Further details are provided under point a). We will also contact you in the event of flight interruptions if you have given your consent to this. We use your personal data solely to be able to answer your personal enquiry. You can decide freely whether to provide your data for the purposes described above. Deutsche Lufthansa asks for your consent that we may also process the personal data that you provide for the use of the chat assistant for other purposes (in particular for advertising purposes).

We also recommend that you act with caution when disclosing especially sensitive data (e.g. information about your beliefs or health).

We use the following personal data when you use the chat assistant or Facebook Messenger:

• Name
• Surname
• Language
• Facebook user name
• Chat assistant user name
• IP address
• Content of your communication
• Personal data about your Lufthansa ID (customer profile)
• Age
• Gender
• Address
• Telephone
• Email address
• Miles & More number
• Miles & More activities
• LHiD
• Booking code
• Ticket number(s)
• Name of accompanying passengers
• Booking class
• ID travel status
• Remarks
• Seat or seat selection
• Lounge access authorisation
• Baggage information
• OSI (additional information)
• SSR (special service requests)
• SSI (special service information)
• APIS (Advanced Passenger Information System)
• IP address
• Search history
• Service preference
• Information via social media
• FeedbackID

 We use the following personal data when you use the chat assistant on Lufthansa.com:

• Name
• Surname
• Language
•  Chat assistant user name
• IP address
• Content of your communication
• Personal data about your Lufthansa ID (customer profile)
• Age
• Gender
• Address
• Telephone
• Email address
• Miles & More number
• Miles & More activities
• LHiD
• Booking code
• Ticket number(s)
• Name of accompanying passengers
• Booking class
• ID travel status
• Remarks
• Seat or seat selection
• Lounge access authorisation
• Baggage information
• OSI (additional information)
• SSR (special service requests)
• SSI (special service information)
• APIS (Advanced Passenger Information System)
• IP address
• Search history
• Service preference
• Language settings on your internet browser
• Personal data about your Lufthansa ID

Cognigy GmbH provides the NLP, which stands for Natural Language Processing and describes techniques and methods for the machine processing of natural language. This data is hosted on Cognigy servers and is not shared with third parties.

If your enquiry cannot be answered satisfactorily, the text you have input is forwarded to the data processing company Microsoft. These input texts will be subject to speech analysis there and compared with a knowledge database. Entries matching the text you have entered will be sent back to you. Microsoft only receives the text you entered during the chat with the chat assistant (including all personal data you disclosed within this context).

We analyse all dialogues to improve the chat function and identify areas for future improvements.

a) Chat function

Only natural persons who are 16 years of age or older are permitted to use the chat assistant.

When you use the chat function, we will use your data as follows:

in the case of an enquiry to Deutsche Lufthansa via Facebook Messenger, Facebook will assign you a session-based pseudonymised user ID. In order to be able to process your enquiry, Facebook communicates this pseudonymised user ID and a user ID that is exclusive to the chat assistant to Deutsche Lufthansa, along with your Facebook user name. This enables us to recognise you if you submit subsequent enquiries via this channel and to contextualise your enquiry in relation to previous chat dialogues. The communication of your Facebook username also allows us to ensure that, in the event of a rebooking, only authorised persons can make this rebooking. The communication of language and gender allows us to address you using a personalised form.

The communication to Deutsche Lufthansa of other data stored by you on Facebook and information about you will not take place. Deutsche Lufthansa stores the user ID provided by Facebook solely for possible anonymised evaluation purposes, such as the collection of user numbers, surveys on language, frequently used areas of the application or similar, in order to be able to make product adjustments and improvements based on these evaluations.

A session-based pseudonymised User ID is assigned if you contact the chat assistant via a webchat. The content of your inputs and the answers from the chat assistant are stored with this User ID.

In order to be able to offer a personalised service, there is an option to link the user ID with your Deutsche Lufthansa customer profile. The purpose of this link is to be able to provide information that is as closely tailored to you as possible, such as on baggage regulations, check-in times, etc. If the user has permitted a link with, for example, their Deutsche Lufthansa customer profile, this information will be stored in the customer database in order to be able to access this information in the event of future enquiries and to be able to provide personalised answers.

Any data you have entered in the chat history of Facebook Messenger in dialogue with the chat assistant will be stored by the commissioned data processor Microsoft, and your data will also be processed by Microsoft for that purpose, as far as is necessary for the handling of your request. If the chat assistant software cannot process your enquiry via a dialogue provided within the software, the data you have entered will be processed using special software. With the aid of this software, your data will be speech analysed and returned again to Deutsche Lufthansa in an analysed form. In each case, the special software only receives the text you entered during the chat history. This also includes personal data that may have been disclosed in the text.

If your enquiry cannot be answered satisfactorily, your input texts will be forwarded to the commissioned data processor Microsoft. These input texts will be speech analysed there with the aid of a special software and compared with a knowledge database. Entries matching your input text will be sent back to you. Microsoft only receives the text you have written within the chat assistant chat (including all personal data that you have disclosed in the same context).

To make the chat function even better, we automatically analyse all dialogues to identify areas for future improvements. Only the content of your dialogues and the respective answers by the chat assistant are analysed. No additional information (such as user IDs, etc.) is included.

b) Push notification function

If you have registered for the chat assistant on Facebook Messenger, you will also receive messages with information about your flight (e.g. information about the departure gate, gate changes, cancellations and rebookings, etc.). If you do not wish to receive these messages, you can unsubscribe at any time without giving a reason.

c) Check-in function

The following personal data is processed if you use the check-in function within the chat assistant:

we require your booking code and surname if you wish to receive a check-in reminder via the chat assistant. You may be asked whether you would like to receive a message as soon as your flight is ready for check-in. You will receive an unencrypted text as soon as your flight is ready for check-in. We will send you an encrypted link which contains personal data (booking code and surname) for the rest of the check-in procedure.

d) Live chat function

We process the following personal data if you use the live chat function of our chat assistant:

You can contact our Service Centre if the chat assistant is unable to process your questions or enquiries. You can also contact our Service Centre via the live chat function. If you use the live chat function, all your personal data will be transferred to our Service Centre and the commissioned data processors Lufthansa Global Telesales, Genesys Telecommunications or Mindpearl, which will answer via Facebook Messenger or the chat assistant on Lufthansa.com.

e) Feedback function

We process the following personal data if you use the feedback function in our chat assistant:

You can send your feedback to us regarding our chat assistant.  Your feedback will be stored combined with your pseudonymised User ID and the content of your conversation.

Declaration of consent

I agree to the processing of the personal data stated above by Deutsche Lufthansa for the use of the chat assistant. This consent can be revoked at any time without giving reasons. It is then no longer possible to use the chat. To revoke your consent, you can select “More” in the Facebook Messenger menu, followed by “Legal & Data Protection” and then click on “Revoke permissions”. Chat can then only be used once consent has been given again.

In order to document the submission of your declaration of consent, we store your Facebook username (first name and surname), gender, your Facebook user ID, your pseudonymised user ID, IP address and the date of submission of your consent.

We store the data sent via the chat assistant as a general rule for 60 days. The storage period will be longer if your personal data is required for the defence, exercise and establishment of legal claims, or if there is a statutory obligation for a longer retention period. The storage period will also be longer if the date of your flight booking is after this period. In this case, your data will be erased if the last flight in your booking has been completed, or after a maximum of six months. The 60-day retention period for the chat assistant function does not affect the retention period for personal data processed for the fulfilment of the contract of carriage. Please refer to our terms and conditions of carriage and our Privacy Policy in relation to the processing of personal data for the fulfilment of the contract of carriage.

In order to process your enquiry via the chat assistant, it may be necessary for Deutsche Lufthansa to transfer your personal data to another affiliated company within the Lufthansa Group, or to an external data processing company (the companies listed in this Privacy Statement or other companies). External processing is carried out solely pursuant to our instructions and in accordance with the statutory provisions. These data processing companies are commissioned to provide servers or send messages, for example.

In addition, we will not send personal data received via the chat assistant to third parties without your consent. We do not sell or rent your personal data. We reserve the right to disclose information about you if required by law, or if we are asked to do so by authorised authorities or the courts.

We have no influence on the type or scope of the data collected by Facebook, which may exceed the context described here. Information about the purpose and extent of the collection, further processing and use of the data by Facebook, as well as your related rights and settings options to protect your privacy, can be found in the Facebook Privacy Policy at https://www.facebook.com/policy.php.

It is very important to us at Deutsche Lufthansa that our methods of data processing are clear and transparent. For this reason it is important that customers are not only able to withdraw their consent, but also to exercise the following rights:

• right of access to the data
• right to rectify personal data
• right of erasure
• right to restrict processing
• right to data portability

An application for data information must be submitted in writing together with proof of identity (scan or copy of an official photo ID). You can send an application for data information by email to ​datenauskunft@dlh.de or by post to:

Deutsche Lufthansa AG
Data Information
FRA CJ/D
60546 Frankfurt
Germany

If you have any questions about data protection laws, please contact the Data Protection Officer of our company by post using the address given above, or by email to ​datenauskunft@dlh.de.

If you have a complaint, you can also contact the relevant supervisory authority for data protection. The relevant data protection authority for Deutsche Lufthansa AG is:

The Officer for Data Protection and Freedom of Information of the State of Hesse
Postfach 3163
65021 Wiesbaden
Germany

Tel.: +49 (0)211 38424-0

Email: ​poststelle@datenschutz.hessen.de

Deutsche Lufthansa uses technical and organisational data security measures to protect your personal data against accidental or deliberate manipulation, loss, deletion or unauthorised access. Data security is a continuous process for Deutsche Lufthansa, to ensure that the technical security measures conform with the current state of the art. Employees of Deutsche Lufthansa are also trained in the fields of data security and data protection, and are subject to organisational measures to ensure secure data processing.

Parts of this Privacy Policy may be amended or updated by us without prior notice. Please always read this Privacy Policy before you avail of our services, so that you are informed about any changes and updates.