We will below explain how we collect, use, transfer, store or otherwise process any personal data relating to you as a Profile Account holder. 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, photo or ID number.
We recognise that special categories of data, such as data revealing ethnic origin, religious beliefs or health information, are particularly sensitive. We will only collect and use such sensitive data only 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’. Even erasing or destructing personal data is to process that data.
The legal basis for our processing of personal data
Your choice to create a Profile Account necessitates SAS to register and process your personal data and your activities while logged in and using our website. We will thus process your personal data on the legal basis that the processing is necessary in order to fulfil our requirements under the Profile Account Terms and Conditions.
We will also process your personal data when we are under a legal obligation to do so and based on our legitimate interests [e.g. reporting to government authorities relating to flight safety or taxation or to prevent fraud through ID control].
What personal data will we process?
SAS registers and processes the following personal data about you and your activities, collectively the “personal data”:
- Personal data submitted when you create, maintain or update the Profile Account.
- Details collected regarding your travels and use of your Profile Account, such as origin and destination for the trip, carrier, type of tickets, luggage, pre-ordered meals, duration of stay, any complaints made, time of purchase, and amounts paid.
Where do we get your personal data from?
The personal data that we process is primarily collected directly from you, e.g. when you enter your contact details to register a Profile Account. In addition, we collect and derive personal data from our flight schedules, airport departments and systems as necessary to fulfil our requirements under the Profile Account Terms and Conditions.
For what purposes do we use the data?
The personal data is registered and processed for the following purposes:
- Administer the Profile Account and bookings etc. made through the account.
- Maintain and improve the functionality of the digital platform.
- Manage and carry out your bookings and travels.
- Update your contact information and cancel/block accounts of deceased customers.
How long will we keep your personal data?
We process the personal data regarding you as long as you are registered with an account. Your personal data is retained until the Profile Account is terminated.
Who may access your personal data?
Your personal data will not be transferred to any third parties and will only be shared within the SAS group. Your personal data may be processed in countries that do not belong to the European Union or the European Economic Area, when you are logged in outside the European Union or the European Economic Area.
The information may be processed in the following countries: [insert relevant countries].
The legal ground for the transfer of data to [insert relevant countries] are [standard clauses?].
Who can I talk to about my personal data and my rights?
SAS [enter corporate identity number and address] is the data controller and legal person which, alone or jointly with others, will determine the purposes and means of the processing of your personal data.
SAS is the legal entity responsible for personal data in accordance with applicable legislation on data protection, including the General Data Protection Regulation (EU Regulation no. 2017/679).
Our designated data protection officer is [name]. The role of the data protection officer is to ensure that our customers’ personal data is processed correctly.
You may contact the data protection officer with any request or question relating to the processing of your personal data, at the following address: [please enter relevant address, such as an address for regular mail purposes or an email address].
What are my rights?
You are entitled to access the personal data that we process on you by contacting our data protection officer. You are also entitled to at any time request that we correct, update or delete data that is incorrect or incomplete.
You may receive a copy of the personal data related to you and data regarding our processing of your personal data by applying to the data protection officer in writing to the address set out above. In such a case, we will provide you with the personal data in a commonly used data format.
By creating a Profile Account, you consented to receive direct marketing from us. You may, however, at any time request that your personal information not be used for direct marketing purposes by using the links in the relevant digital communication or by contacting SAS at [insert email address].
You have the right to lodge a complaint to the data protection authority within your jurisdiction, which in Sweden is the Data Protection Board (Sw. Datainspektionen).
We are committed to protecting your privacy and will only process the personal data that is necessary in order for us to fulfil the Profile Account Terms and Conditions. We will process your personal data as described in this document.
Opening a Profile Account, as governed by the Profile Account Terms and Conditions, is an alternative to becoming a member of our EuroBonus program. You are at any time welcome to enrol in the EuroBonus program, in which we offer a range of easy, joyful and personalised services and offers to make life easier for our members.
When may SAS ask me for my consent?
In certain situations, we will need your consent in order to process your personal data.
We may also ask for your consent to use post, mobile phone, SMS, MMS, email, social media and other digital channels to send promotional communications to you concerning our, or our business partners’, products and services.