Collection and Use of Data
- General
In order to access or request certain functionalities or services available on our website, you may be required to enter information that qualifies as personal data.
Personal data means any information relating to an identified or identifiable natural person (“Personal Data”).
The Controller, Service Alliance for Europe, Divison of Colleon AG, An der Fahrt 8, 55124 Mainz, Germany (“SAFE”) only collects Personal Data to the extent that you provide it to us in relation to specific features in our app or on our website, such as enrolling into and using our Biometrics program or your subscription to our newsletter.
Personal Data may also be collected by third party service providers through external websites to which we provide a link, as shall be described below.
In addition, SAFE collects information in a form that does not, on its own, permit direct association with a specific natural person, such as but not limited to, language choices, your current location (city), or your IP address (to the extent that it cannot be traced back to a specific street address) and user activity on the SAFE website (“Non-Personal Data”). If SAFE combines Non-Personal Data with Personal Data (“Data”), the combined data will be treated as Personal Data for as long as it remains combined.
Personal Data is not collected for any purpose other than for the purposes stated in this Privacy Policy and will not be shared with any third party unless required by the applicable law. Personal Data will not be collected for profiling or other automated decision-making.
The means in which your Data is collected on or through our website, regional websites or linked third party websites shall be described in the following sections.
- SAFE Website
Collection and Use of Personal Data by SAFE for Newsletter Services
Scope and Purpose of Collection
SAFE collects Personal Data in relation to the newsletter subscription service available on certain regional websites.
SAFE collects the following Personal Data:
your first name, last name, email address and optionally your company name.
The purpose of the collection and further processing of your Personal Data is (i) registering your subscription; (ii) providing you, on a regular basis, with selected news articles regarding our Member Carriers; and (iii) sending you, from time to time, special offers made available by our Member Carriers.
Consent
By subscribing to our newsletter, you consented to the processing of your Personal Data for the purpose specified above in accordance with Art. 6, Subparagraph 1(a) GDPR.
You may, at any time, withdraw your consent by unsubscribing from our newsletter by either (i) clicking on the “Unsubscribe” link in the footer of each newsletter you receive, or (ii) visiting the subscription webpage, choosing the ‘Unsubscribe’ option and filling-in your subscriber information.
Your Personal Data will then be automatically deleted from our mailing list and a confirmation email will immediately be sent to you.
Alternatively, you may send us an email at unsubscribe@ch.staralliance.com with your request to trigger the deletion of your Personal Data.
Storage period
Because our newsletter is delivered on a continuous and regular basis, your Personal Data shall be stored as long as necessary for the provision of the newsletter subscription service to you outlined above, unless otherwise notified by you using the unsubscribing means specified above (see ‘Consent’ section).
Secure processing
SAFE shall treat your Personal Data with utmost care and store it securely in accordance with the applicable laws. Therefore, we only use computer systems with limited access housed in facilities using physical security measures.
Your Personal Data will only be available to the limited number of SAFE administrators administering the newsletter.
- Your Rights
Right to Access, Correct or Delete (Art. 15-17 GDPR)
You have the right to access your Personal Data by requesting a copy of it using the contact details indicated below. You also have the right to demand its correction or deletion using the same means of communication.
Right to Restrict/Object (Art. 18 GDPR)
In addition, you have the right to restrict/object to the processing of your Personal Data and withdraw your consent to its future processing.
Right to Personal Data Portability (Art.20 GDPR)
You further have have the right to receive the Personal Data you have provided to SAFE, in a structured, commonly used and machine-readable format and to transmit those Personal Data to another controller. Where technically feasible, you may request SAFE to transmit the Personal Data directly to the other controller of your choice.
Complaints (Art. 77 GDPR)
You have the right to lodge a complaint of an alleged infringement of the applicable data protection laws with the supervisory authority pursuant to Art. 77 GDPR in combination with Art. 19 GDPR. The relevant supervisory authority for SAFE is:
The Officer for Data Protection and Freedom of Information of the State of Hesse
Postfach 3163
65021 Wiesbaden
Germany
- Collection and Use of Non-Personal Data by SAFE
Website Feedback
When you use the opportunity to share user feedback by clicking on the ‘Website Feedback’ button, please note that no Personal Data is required or should be included in your message. SAFE does not collect and will immediately delete any Personal Data that you provide as part of this feedback function.
Certain Non-Personal Data, such as your IP address, device information, city and language, is collected by default together with your feedback and stored on third party servers. This information is made available to a limited number of SAFE staff for analytical purposes and cannot be traced back to any individual.
Lounge Survey
Our lounge survey for lounge customers only collects the IP address of users for analytical purposes.
- Contact Details
If you want to exercise your legal rights or have any questions or concerns about this Privacy Policy, please contact us or our Data Protection Officer by using the following channels:
Postal Address:
Colleon AG
Service Alliance for Europe
An der Fahrt 8
55124 Mainz
SAFE Data Protection Officer: privacy(at)safe.ag
- Changes to this Policy
SAFE reserves the right to make changes and amendments to this policy from time to time in accordance with the applicable laws. Any material changes in the way we use your Data will be posted on this page.
For any material changes in the way we wish to use your Personal Data we will ask for your consent.