I. GENERAL PROVISIONS
The protection of our customers’ privacy is very important to SWISS. Hereinafter, we set out the principles we follow and for what purpose we collect and process personal data (information that determines your identity or allows us to identify you; referred to hereinafter also as “data”) via this website, and other websites and applications (referred to hereinafter as "website") operated by SWISS.
We collect and process your personal data carefully, only for the purposes described in this Privacy Statement and only to the extent necessary as defined therein and within the scope of the applicable legal regulations. We only store your personal data to the extent and as long as it is required for the performance of our services or as we are legally obligated.
Under Section I you will find the general data protection information, under Section II, the provisions with regard to data processing in connection with carriage, and under Section III you will find further instances where data processing is used.
B. Use of the website and cookies
You can visit the website and obtain information about our offers without disclosing personal data. We only request personal data where required for the performance of our own services and for the processing of transactions that you carry out with SWISS or our partners.
When you access our website, our system automatically records technical information about the computer accessing it. The data collected is information about the browser type and the version used, the operating system, the internet provider and the IP address of the user, the date and time of access, the websites from which the user’s system obtains access to our website, and the websites accessed by the user’s system via our website.
C. Storage of customer data
For accounting reasons, SWISS generally stores the personal data collected from customers for processing bookings for 10 years after the last processing operation. We store other data as long as is necessary for the execution of the contract and to safeguard our rights. We reserve the right to apply longer statutory and operational storage requirements and reasons.
Personal data collected for marketing activities is generally deleted as soon as the purpose of the activity has been met.
D. Data security
We protect your personal data by means of appropriate technical and organisational security measures and store it solely on our secure servers. The website is secured against loss, destruction and manipulation by means of customary measures in accordance with the state of the art and against access, modification or distribution by unauthorised persons. Especially sensitive data (e.g. access data for your profile account) is encrypted during transmission via the internet (SSL).
However, SWISS does not assume any guarantee for the security of your data. It is your responsibility to make an up-to-date back-up of the transferred data at all times and store it separately from the website. You are also responsible for creating a secure password for your customer account, keeping it safe and changing it on regular basis.
E. Rights of customers
You have the right to information, correction, deletion and transferability of your data. Furthermore, you have the right to restrict processing.
Paragraph C (Storage of customer data)and other statutory exceptions are reserved.
You have the right to object to the processing of your personal data. An objection only has future effect and does not affect previous processing. If, on account of the objection, SWISS is no longer able to perform the services contractually agreed with you, the objection is deemed to be a breach of contract by the customer and SWISS has the right to terminate its contract with you without notice. Payment obligations already contractually entered into by the customer remain in force.
For the assertion of these rights, you can contact SWISS at the address given in paragraph F (Contact).
If SWISS does not comply with the applicable data protection law, you have the right to file a complaint directed at the competent regulatory authority.
If you have any questions about this Privacy Statement or regarding data protection at SWISS, please contact:
Swiss International Air Lines Ltd.
Betrieblicher Datenschutzverantwortlicher (data protection officer)
CH-8058 Zurich Airport
G. Representative in the European Union
Swiss International Air Lines Ltd.
Cargo City Süd 558
60549 Frankfurt am Main
We review our Privacy Statement regularly and update it as required. We will inform you of any important changes (e.g. on our website).
II. PROCESSING OF PERSONAL DATA IN CONNECTION WITH CARRIAGE
A. Purpose of data processing
SWISS processes the personal data of its customers for the purpose of carriage, which includes in particular
- management of check-in
- communicating with the customer with regard to carriage
- operation of the flight
- simplifying of immigration procedures
- processing of irregularities in relation to baggage
- improvement of offers from SWISS and its positioning in the market and
- securing payment transactions (also referred to hereinafter as “carriage”).
B. Sharing of data with the authorities in Switzerland and abroad
- 1. Definition of API and PNR data
API data (“Advanced Passenger Information”) is basic information about passengers that is required by certain government authorities for entering and leaving the country. It includes the name, date of birth, sex, nationality, travel document data and e-mail address of passengers. API data also includes other data, such as flight information (e.g. flight number and arrival and departure times).
PNR data (“Passenger Name Record”) is all the information and data required for carriage (e.g. booking code, name, e-mail address, flight information, payment information and details of travelling companions), plus any additional data in connection with carriage, in particular information sent by you (e.g. frequent flyer information or special requests) or third parties (e.g. travel agencies).
- 2. Disclosure to authorities
For legal and regulatory reasons, it is necessary that we share certain personal and booking information (including API and PNR data) with the governmental authorities in Switzerland and abroad.
- 2.1 Security and entry
For security reasons and to verify the entry formalities, the authorities in some countries require data about travel to and from these countries, as well as for overflights above their territory. In this context, SWISS is obliged to transfer your API and PNR data to domestic and foreign authorities. Such data is transferred based on intergovernmental agreements or national laws. Data of this kind is generally required by the authorities in the country of departure and arrival.
For example, under US law the border authorities (U.S. Customs and Border Protection) receive your personal information and information related to your trip when you book a flight between Switzerland and the USA. The US authorities have given the same guarantees with regard to the use of data to Switzerland as they have to the European Union; they will only use the information for combating terrorism and other serious, crossborder criminal offences. The data is stored for at least three years and six months and may also be shared with authorities in other countries. You can find additional information on the use of your data by foreign authorities and the measures to protect your data at www.cbp.gov.
- 2.2 Investigative activities
SWISS is obliged to share your personal data with criminal prosecution, administrative or judicial authorities in Switzerland and abroad in case they require its disclosure for the prevention or prosecution of crimes, misdemeanours, or comparable administrative misconduct. Such a transfer is only performed if based on legal or regulatory requirements.
C. Credit assessment and anti-fraud measures
We reserve the right to verify payment transactions in order to prevent fraud and other improper usage. To this end, we use both internal and external sources of information. For this purpose, we also use distinct, identifiable technical features. If fraudulent activity is suspected and/or detected, we also reserve the right to share the relevant information (including personal data) with other subsidiaries of the Lufthansa Group, who may also verify the data for their own purposes.
For use of the payment service "purchase on account", see SectionIII paragraph I (Purchace on account).
D. Data processing by third parties in Switzerland and abroad
SWISS allows personal data to be processed by third parties in Switzerland and/or abroad (also in countries where legislation does not guarantee appropriate data protection) for the purpose of operating the website and to meet the purposes stated in this Privacy Statement.
In the case of the transfer of data to countries without appropriate data protection, SWISS ensures that the measures required are implemented (generally by signing recognised data protection agreements, e.g. based on standard contractual clauses of the EU), in order to protect personal data in accordance with the applicable data protection law.
- 1. External data recipients
External recipients of personal data include
service providers in the areas of ground handling, transport, marketing, customer feedback, IT,
payment services and credit agencies,
platforms for sending newsletters,
operators of live help chat,
companies of the Lufthansa Group,
airlines outside the Lufthansa Group,
partner companies as well as
government offices and authorities.
- 2. Combating fraud and “unruly passengers”
“Unruly passengers” are passengers who display improper, aggressive or violent behaviour towards other passengers or the crew, or who damage the aircraft.
SWISS is entitled to exchange its passengers’ personal data within the Lufthansa Group and with other airlines in order to document, analyse and prevent cases of fraud and instances of "unruly passengers", and to process the data relating thereto.
If you have harmed or injured other passengers, SWISS can also disclose your personal data and information in connection with the harm and injury to other third parties (e.g. the authorities, injured persons and insurance companies).
III. APPLICATION CASES
A. Swiss.com profile
- 1. Purpose of the swiss.com profile
You have the option of creating your own swiss.com profile on the website. Your swiss.com profile allows you to carry out flight bookings and use other booking services more easily, such as advance seat reservation, online check-in and inflight entertainment, and also to receive other offers from SWISS and its partner companies.
If you have given your consent to digital communications, you will also receive promotional content from the following SWISS partner companies:
Cartrawler, Hotels.com, Viator, Naka Mobile, SBB, Starticket, Swiss Holidays, Swiss Shop, MyClimate, CHECK-IN all-ways
- 2. Personal data collected for the creation and operation of your profile
When you set up a swiss.com profile, we ask for your personal data, in particular your surname, first name, date of birth, telephone number and e-mail address. However, only the entering of your e-mail address is compulsory. To set up your profile we use the so-called double optin procedure: After you have registered, we send you a notification e-mail. You can confirm the setup of your profile by clicking on a corresponding activation link.
In order to process flight bookings you have made that are operated by SWISS or our partners, you can also store the following additional information in your profile: Your preferred payment method, your address and your Miles & More membership number. If you decide not to store certain additional information in your swiss.com profile, you may be unable to access some specific functions or transactions.
SWISS is entitled to process the data you share with us as part of the use of your swiss.com profile, so that we can meet the resulting contractual obligations and operate your swiss.com profile.
- 3. Sharing of data within the Lufthansa Group and with third parties
SWISS will collect and process the data you share with us in your swiss.com profile and/or during your use of a function of the swiss.com profile and which is required for the use of your swiss.com profile (e.g. personal data, non-personal data and information) within SWISS, and may transfer data to companies of the Lufthansa Group, of which SWISS is also a part, for the purposes stated in this Privacy Statement. In addition, third-party companies designated by SWISS for the technical management of the swiss.com profile may also obtain access to your data in the course of this activity.
- 4. Marketing activities and personalised advertising
At SWISS it is our ambition to offer you an air travel experience that is customised for you, your personal wishes and expectations, from your very first visit to our website and even beyond the end of your trip.
- a. Marketing and analytical activities
For this purpose, SWISS processes your personal data collected in the course of registration and use of your swiss.com profile for marketing and analytical activities. As part of its marketing and analytical activities, SWISS may send you offers, for instance about SWISS products and services which are similar to or the same as others you have purchased or used previously. If you do not wish to receive such offers, you can delete your swiss.com profile at any time.
- b. Personalised information and offers
When you set up a swiss.com profile, we combine data about your consumption and usage patterns with SWISS and companies of the Lufthansa Group and analyse it, in order to provide you with relevant, personalised information and offers tailored to your interests (e.g. recommendations for specific flights or information on baggage conditions). By setting up your swiss.com profile, you agree that we may provide you with such information and offers. We will only collect, process and use additional personal data from other sources (e.g. from websites operated by third parties) to create personalised information provided that you have given such third parties consent to this effect.
- c. Market research
As part of our market research activities, SWISS may invite you to take part in surveys to improve our products and services.
- d. Electronic communication
By setting up a swiss.com profile, you give us permission to send you relevant information, recommendations and offers from SWISS and companies of the Lufthansa Group. This takes place by means of non-analogue communication, such as e-mail, telephone, SMS or instant messaging, for example. If you do not wish to receive such communications, you can delete your swiss.com profile at any time.
- 5. Link to a frequent flyer programme
Once you have set up your swiss.com profile, you can add a frequent flyer programme from our cooperation partners. You can find out who our cooperation partners are in the selection list during or after setting up your profile. If you set up a link, the frequent flyer number and the frequent flyer PIN number are processed in addition to the data entered in the swiss.com profile. Linking your swiss.com profile with a frequent flyer programme is voluntary and therefore only takes place with your consent.
SWISS is the co-publisher of the Miles & More programme. If you are also a member of the Miles & More programme, please bear in mind that your swiss.com profile is not linked with your Miles & More account. We therefore ask that you follow the data protection information from Miles & More GmbH.
Linking your swiss.com profile with a frequent flyer programme can only be cancelled by deleting your swiss.com profile.
- 6. Deleting your swiss.com profile
You can delete your swiss.com profile at any time and without giving reasons. Your profile can then no longer be used and reactivated.
If you delete your swiss.com profile, SWISS will fully delete or anonymise the personal data contained in your profile. Statutory and operational storage requirements or reasons are reserved by SWISS.
Upon request, we will keep you informed about relevant developments and offers from SWISS. We use the so-called double opt-in procedure to subscribe to our newsletter: When you subscribe to our newsletter on the website, for example by clicking a confirmation field, we will send you a notification e-mail. You can confirm your subscription by activating the relevant link. If you no longer wish to receive newsletters from SWISS, you can either unsubscribe free of charge in the newsletter itself or in your swiss.com profile, at any time. Doing so will not restrict the use of your swiss.com profile.
We process your data associated with the newsletter in order to send you news about and related to SWISS and our partners. In addition, we also process and use the e-mail address you have entered in order to send you personalised offers associated with the newsletter.
If a link in the newsletter directs you to our websites, you also give us permission to process and use your IP address, together with geodata, web beacons or similar technologies, in order to verify whether the offers presented to you in the course of this communication meet your requirements.
SWISS works together with external service providers for the dispatch of the newsletter.
C. Customer satisfaction surveys
In the course of analytical activities and in order to offer you a better customer experience, SWISS may ask you to take part in customer satisfaction surveys after you have completed your SWISS flight. If at a later date you no longer wish to receive such offers or requests, you can unsubscribe from these free of charge at any time via the link provided in the corresponding e-mail.
D. Customer panels
With its online customer panels, SWISS gives you the opportunity to let us know your opinion on specific subjects related to products and services offered by SWISS. To take advantage of this, you can register for the customer panel.
Members of the customer panel are invited at regular intervals, via e-mail, to take part in market research projects, such as brief online surveys, focus groups, product tests and indepth interviews, for example. The information provided by a member about his/her person, address, age, gender, nationality, professional background and travel behaviour and habits is used to identify suitable surveys for the member.
Participation in market research surveys is always voluntary. You have the option of ending your participation in the customer panel at any time by sending an e-mail to email@example.com
The information received in the course of a market research project is only analysed in anonymised form. It is not published or used for marketing purposes.
SWISS works with an external service provider which has access to the personal data for the administration of the surveys and evaluation of the opinions. The service provider supplies the software used to collect opinions, which are then anonymised.
E. Live chat service
SWISS provides you with online advice on swiss.com in the form of a live chat service. SWISS works together with an external service provider for the operation of the live chat service. The service provider sees your details during a chat session on the SWISS website (collected via a cookie of this tool) that helps him/her to assist you. In addition, the service provider has access to the SWISS passenger database (e.g. database with bookings and reservations) and can check certain data on your behalf if you give your name to the service provider and ask the service provider to check it.
SWISS is offering online advice in the form of automated chat (chatbot) on some of its Facebook pages. SWISS is working together with external service providers for the operation of the live chat service. During a chat, information from your Facebook profile (e.g. name, language) as well as your respective input will be processed in the Facebook Messenger Chat. If the chatbot cannot process your request itself, the chat will then be handed over to a member of our customer service team at your request. These members of our customer service team can view the past chat history and see your Facebook profile name.
G. Bid Upgrade
On certain destinations SWISS offers you a Bid Upgrade. It gives you the chance to bid an amount of your choice for an upgrade into a higher compartment. SWISS offers you this service in cooperation with an external service provider. In order to perform the process, SWISS transmits flight relevant information (name, e-mail address, flight information, original compartment) as well as the amount of your bid with the provider to ensure that, in case your offer is accepted, your upgrade is assigned to your original ticket and your ticket is adapted accordingly. For further details regarding data processing in relation to the service Bid Upgrade, please refer to www.plusgrade.com.
H. Offers from third parties in the scope of carriage
In the scope of the carriage, SWISS will show you offers from third parties (e.g. from hotels or car rental companies) on its website; these offers are created on an anonymous basis. If you have given us your consent to this effect, we will also show you such offers as part of the communication before your departure.
While booking, SWISS will offer you travel insurance on its website, provided by a third party. If you obtain the insurance (i.e. if it is "ordered" online), SWISS receives data from you, performs the billing directly on behalf of the third party (payment is made to SWISS) and sends data to the third party, such as the name of the person applying, the length of the trip and the booking code. The third party then sends you an e-mail with the relevant policy, of which SWISS also receives a copy.
J. Booking process
If you start a booking process, we collect booking data and personal data, in particular your surname, first name, date of birth, telephone number, e-mail address and, in encrypted form, your credit card details.
K. Purchase on account
In order to use the “purchase on account” payment service, SWISS processes your personal data (e.g. first name and surname, address, date of birth, e-mail address and mobile telephone number, as well as information on the outstanding amount, the currency used and the booking data), besides the usage data of your website visits to SWISS (e.g. information about the start, end and scope of the websites you visited, your IP address and click paths). The basis for processing is created by cookies and/or a visitor ID, which may include anonymous data regarding the end devices you used when visiting the websites (e.g. your screen resolution or the version of your operating system). SWISS can transfer such data to third-party companies engaged to provide the “purchase on account” payment service and have this data processed by such companies.
If you select the “purchase on account” payment service, your data is used and processed for the purpose of providing this payment service, for identity and credit worthiness checks (this may also include obtaining references from other third parties, such as credit agencies) and for risk management (including fraud and abuse prevention and also with the involvement of further third-party companies). If there is any suspicion of fraud, SWISS will verify the assessment and the underlying evidence. You will be informed if your application has been declined.
You may cancel this agreement with SWISS informally with future effect and at any time. Any further use of the “purchase on account” payment service will then no longer be possible. The identity, credit worthiness and fraud checks carried out for the “purchase on account” payment service are governed solely by the provisions of the respective third-party company.
L. Golf Traveller
You have the option of taking out a SWISS Golf Traveller membership in order to enjoy benefits and price reductions in connection with golf trips. For registration we ask for your first name and surname, address, telephone number, e-mail address, date of birth, Miles & More number and information for processing payment.
If you choose the option of receiving an additional SWISS Miles & More American Express Golf card, we also collect your nationality, your legal residence status, your employment (incl. your employer) and your gross annual income.
SWISS Golf Traveller membership can also be given as a gift. In this case, the person giving the gift must provide the above-mentioned personal data about the recipient, with the exception of information for processing payment. Once the person receiving the gift obtains the SWISS Golf Traveller membership, the name of the giver is disclosed.
M. SWISS app
With the SWISS app, SWISS provides you with the option of searching for flight information, booking flights, loading your flight bookings into the app, carrying out check-in procedures and displaying boarding passes and temporarily storing them. In order to obtain information on a flight booking, you must enter your booking code or the flight number, or log in using your swiss.com profile. Once you have logged in, you receive a summary and further information on bookings linked to your profile. This data is stored temporarily in the app in protected form and is deleted as soon as it is no longer visible in your swiss.com profile. The login data is transferred to SWISS by the app to identify the user.
N. Sponsorship and cooperation requests
For the purpose of verifying and processing requests related to a potential sponsorship/partnership relationship, SWISS processes the personal data of the applicants.