Data protection notice and declaration of consent

The protection of your privacy is our paramount priority. We would like to inform you below how your personal data will be processed by the SWISS Chatbot on the service provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter “Facebook”) known as Messenger (hereinafter “Facebook Messenger”).

Some of the provisions below may deviate from and/or supplement the general data protection provisions of SWISS (which can be viewed at: ​SWISS privacy statement). In case of deviations to the SWISS privacy statement, this data protection notice has overriding priority.

Data Controller (hereinafter “Controller”) is

Swiss International Air Lines AG

Malzgasse 15

CH-4052 Basel

Switzerland

(hereinafter “SWISS”)

Tel: +41 (0)848 700 700

Web: www.swiss.com

Microsoft Ireland Operations Limited

Atrium Building Block B

Carmenhall Road

Sandyford Industrial Estate

Dublin 18,

Ireland

Bertelsmann Arvato

Arvato Direct Services GmbH

An der Autobahn 2

33333 Gütersloh

Germany

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 Island

Data subjects are customers and others with their own Facebook account who use the Facebook page ​www.facebook.com/flySWISS/ and the Facebook Messenger function to enter into a dialogue with the SWISS Chatbot to obtain information about flights and further products, services and aspects of SWISS (hereinafter the “chat function”). A Chatbot is a computer system that interprets and automates written chat text and responds to the written question or inquiry submitted. In addition to this chat function, Chatbot users may also register themselves to be updated on the status of their booked flight(s) and/or receive other operational information. The notifications provided are also sent via Facebook Messenger.

In addition to the chat function, customers also have further ways to obtain information and services from SWISS such as Service Centers or the company website.

Personal data is every information that identifies a natural person or makes a natural person identifiable.

SWISS will only use your personal data to provide you the functions of the Chatbot via Facebook Messenger as described here in Section 4a) below. We will only use your personal data to process your particular question, inquiry or request. It is entirely up to you whether you wish to provide us with such personal data for the purposes concerned. SWISS will not use the personal data for any other purpose without your prior written consent.
We also advise you to exercise caution with any particularly sensitive personal data (such as details of your health or your religion) when using the Chatbot facility.

We use the following personal data:

• First name
• Last name
• Gender
• Language
• Facebook User Name
• Facebook User ID
• Chatbot User ID
• IP Address
• Booking code
• E-Mail
• Phone Number
• Contents of your messages (inquiries, etc.)
• Personal data of your SWISS user profile
  
  

a) The chat function

Kindly note that it is only allowed to use the Chatbot upon attending the age of 16 years.

If you use the Chatbot’s chat function, we will use your personal data as follows:

If your inquiry to SWISS is made via Facebook Messenger, Facebook will issue you with a session-based anonymized user ID. To process your inquiries, Facebook will transmit this pseudonymized user ID to SWISS together with an exclusive Chatbot user ID and your Facebook user name (first and last name) as well as gender and language. This will enable us to identify you again if you send any further inquiries via this channel, and will allow us to view and handle these in the context of our previous communications. The provision of your Facebook user name will further enable us to ensure that, in the event of a rebooking, the rebooking concerned can only be made by the person(s) entitled to do so. The provision of language and gender will allow us to address you in a more personalized manner.

No further personal data or information of your Facebook Account will be transferred to SWISS. SWISS will store the above mentioned informationprovided by Facebook only for evaluation purposes that are anonymized such as user volumes, breakdowns by language or areas of application or similar, with a view to further enhancing the Chatbot service.

For a personalized service, we also offer the option of linking your user ID with your SWISS customer profile. This will enable us to tailor our response to your inquiry as closely as possible to your person – for baggage provisions, check-in times or similar. If you choose to link your user ID to your customer profile at SWISS, for instance, this information will be stored in our customer databases, to enable us to draw on it again for future inquiries and offer you responses that are personalized.

All the data from your chat-function dialogue with the Chatbot via Facebook Messenger will be stored and processed by the data processor Microsoft. Insofar as this data is required to process your inquiry, it will also be processed by Microsoft to this end. If the Chatbot is unable to process your inquiry via a dialogue envisaged by and provided in its software, the data you have entered will be linguistically analyzed by a special software application and returned to SWISS in duly analyzed form. In such cases, only the text you entered in the course of your Chatbot chat (including any personal data which you may have provided in the same text) will be analyzed.

In case that your inquiry cannot be answered sufficiently, the data you have entered will be sent to the data processor Bertelsmann Arvato, where it will be linguistically analyzed by a special software application and matched with a knowledge database. Information matching your inquiry will be sent back to you. In such cases, Bertelsmann Arvato will only receive the text you sent to the Chatbot chat (including any personal data which you may have provided in the same text).
In order to improve the chat function, we analyze all dialogues in an automated matter to highlight areas for future improvements. Solely the content of your dialogues and the respective responses from the chatbot will be analyzed and no additional information (such as user names etc.) will be taken into consideration.

b) Push Notifications

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

c) Additional option: the “check-in reminder” function

If you use the Chatbot’s check-in reminder function, we will use your personal data as follows:

If you want to be reminded to check-in of your flight, you have to provide us your booking code and last name. You may be asked if you want to be reminded when check-in is open. Once check-in is available, we will then send you a notification to check-in. We will also provide a link that you can follow if you wish to check-in. This link will contain your personal details in order to facilitate your check-in process.

d) Additional option: the “live chat” function

If you use the Chatbot’s live chat function, we will use your personal data as follows:

In situations where the chatbot cannot answer your question/request/inquiry, it can offer you the option to be forwarded to a human service center agent. You may also reach this agent by entering a request such as “live chat”. Once confirmed, we will pass on your information to a service center agent who will then answer to you directly in Facebook messenger. Your dialogues will thereby be sent to the data processors Lufthansa Global Telesales or Mindpearl.

e) Additional option: the “feedback” function

If you use the Chatbot’s feedback function, we will use your personal data as follows:

You also have the option to rate your conversation with the chatbot and provide feedback. You will be invited to do so occasionally but also have the option to enter “feedback” and follow the subsequent steps. The feedback you provide will be sent via unencrypted email to the responsible departments. It will not contain personal details apart from your pseudonymized user ID.

Declaration of consent

I give my consent to SWISS to process my above mentioned personal data to use the chatbot via Facebook Messenger. I may revoke this consent at any time and without any stated reason. However, I accept that in this case the chatbot will no longer be available until I give valid consent again. To revoke your consent, you can select "More" from the Facebook Messenger menu, followed by "Legal & Data Protection" and click on "Revoke permissions". Use is then only possible after renewed consent.

To document your given consent, we store your first name, last name, gender, Facebook user ID, pseudonymized User ID, IP-address as well as the timestamp of your consent.

Your personal data, which were processed in the context of the chatbot, will be deleted after 60 days, unless your personal data are necessary for the establishment, exercise or defence of legal claims. The storage period is longer if the date of a flight booking you have entered exceeds this period. In this case, your data will be deleted when the latest flight in your booking is reached, or after a maximum of 6 months. The 60 days retention period of the chatbot functions does not affect the retention period of all personal data processed to fulfill the contract of carriage. With regard to the processed personal data to fulfill the contract of carriage kindly note our terms and conditions of transport as well as the privacy policy in this context. The retention period may be longer if a legal retention period applies.

SWISS may transfer, in the course of processing your Chatbot inquiry, your personal data to other affiliated companies within the Lufthansa Group or to data processors (both named specifically in this data protection notice and not named herein) acting solely on our behalf and in compliance with all the relevant legal provisions. Such external providers may include, for example, those commissioned to provide the servers concerned, or those transmitting our news messages.

Apart from the above, we will not transfer any personal data to any other third party without your prior consent, and will never sell or rent out your personal data. However, we reserve the right to disclose your personal data if we are compelled to do so by law or if such disclosure is demanded of us by legally empowered bodies or prosecuting authorities.

We have no influence of the nature or the scope of the data which may be collected by Facebook through your use of the Chatbot via Facebook Messenger. For the scope and the purpose of such data collection by Facebook, for Facebook’s further use and processing of such data, for your rights relating to the same and for the Facebook settings available to you to protect your data privacy, please note the Facebook Privacy Policy, which you will find at ​https://www.facebook.com/policy.php.

It is important for SWISS to make our data processing clear and transparent. Our customers are not only able to withdraw their consent, but may also to exercise the following rights:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability

You must submit your information request with proof of your identity (scan or copy of an official photo ID) to ​dataprotection@swiss.com. You can also send your information
request by post to:

Swiss International Air Lines Ltd.

Data Protection Officer

ZRHS/CJ

Postfach

CH-8058 Zurich Airport

Switzerland

You also have the right to file a complaint with the Data Protection Authority as the supervisory authority with jurisdiction. The data protection authority with jurisdiction for SWISS is:

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit

Postfach 3163

65021 Wiesbaden

Telefon: +49 611 1408 - 0

SWISS implements technical and organizational data security measures to protect your personal data against incidental and willful manipulation, loss and destruction, and against access by unauthorized persons. Data security measures at SWISS are continuously evolving to ensure our technical security procedures reflect the latest standards in technological development. At the same time, our staff at SWISS is trained in data privacy and are subject to organizational data security measures to protect your privacy rights.

Parts of this data protection notice may be amended or updated by us without prior notification. Please always consult our data protection notice before you use the relevant products and services to ensure that you are fully aware of the latest status hereof.

Latest version of this data protection notice: May 2019