Data protection notice: Cargolux Marketing & Communications
Cargolux International Airlines S.A. Luxembourg Airport, Luxembourg (hereafter referred to as “Cargolux” or “We”) is committed to protecting the personal data of our customers, prospects, and more generally, of any data subject concerned by our processing activities (hereafter referred to as “You”).
This Data Protection Notice explains how we process your personal data, complying with the rules currently stated in the General Data Protection Regulation EU 2016/679 (hereafter referred to as the “GDPR”) on the protection of individuals with regards to the processing of personal data and on the free movement of such data.
Who is the controller of your personal data?
Cargolux is responsible for collecting and processing your personal data in relation to sending You marketing materials and communications.
What personal data will Cargolux process and why do we process it?
We may process various types of personal data about You:
- Name, surname
- Username
- Job title and name of the company You are associated with
- Business email address
How do we collect your personal data?
We may collect the categories of personal data mentioned above by various channels:
- We collect the personal data that You provide directly to us.
- We may also receive information from social network that You have made public (e.g. LinkedIn).
What are the purposes and the legal basis for Cargolux's processing activities?
The information we request from You is considered as the minimum necessary data enabling Cargolux to pursue the purposes described below:
- To send You our Monthly Newsletter & share relevant market information with You.
- To connect and interact with You on social media or when You react to publications or comment boards of the newsletter to which You can post (Please note that information posted on these boards will be available to the public).
The legal basis for the processing of your personal data is legitimate interest, to perform email marketing, provide You with information on network developments, improvements to our services, fleet developments, updates on embargoes, customs requirements, fuel surcharges, as well as to perform market research.
If You have subscribed directly to the Monthly Newsletter on the Cargolux Website, the legal basis for the processing of your personal data is consent. You can withdraw such consent at any time by contacting us directly.
If You do not want Cargolux to process your personal data for the purpose of sending You marketing emails and newsletters, You have the possibility to opt-out by clicking the Unsubscribe button at the end of the email, or by contacting us directly.
Who do we share your personal data with?
We may disclose your personal data:
- to members of Cargolux on a need-to-know basis.
- to third parties providing services to us, namely, website hosting, IT services and other similar services to enable them to provide their services.
- to third parties outside the Cargolux group, if obliged by competent authorities as per the applicable laws.
How do we protect your personal data?
We have implemented technical and organizational security measures to protect your personal data from unauthorized access, improper use, alteration, unlawful or accidental destruction and loss.
Nevertheless, no data transmission or storage over the internet can be guaranteed to be 100% secured. If You feel that the security of any account You might have with us has been compromised, please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.
Where do we transfer your data to?
Your personal data are processed by us within the European Union.
In case of international transfers originating from the EU/EEA to a country outside the EU/EEA, the transfer of your personal data may occur where the European Commission has determined that the country outside the EU/EEA ensures an adequate level of data protection. For transfers to countries outside the EU/EEA for which the level of protection has not been recognized as adequate by the European Commission, Cargolux will implement appropriate safeguards provided for by current data protection law (e.g. the entry into standard data protection clauses) or rely on a derogation applicable to specific situations.
For how long do we keep your data?
Cargolux does not keep your personal data for any longer than is necessary. The duration of retention depends on the purposes for which data are processed as described below:
- Data used for marketing purposes will be deleted as soon as no longer accurate or as soon as You exercise your rights as detailed below.
After this retention period, the data will be erased from Cargolux’s system.
What are your rights?
In accordance with the applicable data protection laws (and subject to conditions and restrictions set forth therein), You may exercise at any time the following rights in relation to your personal data:
- Right of access, which enables You to obtain from us confirmation of whether your personal data is being processed or not and, if so, obtain access to such data (considering we process a large quantity of information; when exercising your right of access You should specify the transaction, information or processing activities to which your request relates)
- Right to rectification, which enables You to obtain from us the correction and/or integration of any of your personal data that are incorrect and/or incomplete;
- Right to erasure, which enables You, in specific cases provided for by art. 17 GDPR, to obtain from us the erasure of your personal data;
- Right to restriction of processing, which enables You, in the specific cases provided for by art. 18 of the GDPR, to restrict the processing of your personal data by us;
- Right to object, which enables You to object to the processing of your personal data when certain conditions are met;
- Right to data portability, which enables You, in certain cases (subject in particular to technical feasibility) and only with regard to the data You have provided to us, to request receipt of your personal data in a structured and commonly machine-readable format.
If You have provided your consent to the processing of your personal data, You can withdraw such consent at any time.
If You no longer want to receive our newsletter and related marketing materials, please use the Unsubscribe option in the mailings.
To exercise any of these rights, You may contact us by email dataprotection@cargolux.com or by postal mail:
Cargolux Airlines International S.A.
Compliance Department
Luxembourg Airport
L-2990 Luxembourg
Luxembourg
You have the right to lodge a formal complaint with the relevant Data Protection Authority (in Luxembourg, Commission Nationale pour la Protection des Données “CNPD”).
This Data Protection Notice may be modified to reflect changes on the Website or on our processing activities, to comply with legal amendments, or to integrate best practices. Updates of the Data Protection Notice will be published on our Website.