Privacy Policy

Personal data (usually referred to just as "data" below) will only be processed by us to the extent necessary and for the purpose of providing a functional and user-friendly website, including its contents, and the services offered there.

Per Art. 4 No. 1 of Regulation (EU) 2016/679, i.e. the General Data Protection Regulation (hereinafter referred to as the "GDPR"), "processing" refers to any operation or set of operations such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction performed on personal data, whether by automated means or not.

The following privacy policy is intended to inform you in particular about the type, scope, purpose, duration, and legal basis for the processing of such data either under our own control or in conjunction with others. We also inform you below about the third-party components we use to optimize our website and improve the user experience which may result in said third parties also processing data they collect and control.

Our privacy policy is structured as follows:

I. Information about us as controllers of your data and about the Data Protection Officer
II. The rights of users and data subjects
III. Information about the data processing

 

Analysis tools and third-party tools

When you visit this website, your surfing behavior can be statistically evaluated. This is mainly done with so-called analysis programs.

You can find detailed information on these analysis programs in the following data protection declaration.

 

I. Information about us as controllers of your data and about the Data Protection Officer

The party responsible for this website (the "controller") for purposes of data protection law is:

Lübeck Air GmbH
Blankenseer Straße 101
23562 Lübeck
Deutschland

Telefon: +49 451 3171-9000
E-Mail: info@luebeck-air.de

The controller's data protection officer can be reached via:

Blankenseer Straße 101
23562 Lübeck
Deutschland
Telefon: +49 451 3171-3190
E-Mail: datenschutz@luebeck-air.de

 

II. The rights of users and data subjects

With regard to the data processing to be described in more detail below, users and data subjects have the right

• to confirmation of whether data concerning them is being processed, information about the data being processed, further information about the nature of the data processing, and copies of the data (cf. also Art. 15 GDPR);
• to correct or complete incorrect or incomplete data (cf. also Art. 16 GDPR);
• to the immediate deletion of data concerning them (cf. also Art. 17 DSGVO), or, alternatively, if further processing is necessary as stipulated in Art. 17 Para. 3 GDPR, to restrict said processing per Art. 18 GDPR;
• to receive copies of the data concerning them and/or provided by them and to have the same transmitted to other providers/controllers (cf. also Art. 20 GDPR);
• to file complaints with the supervisory authority if they believe that data concerning them is being processed by the controller in breach of data protection provisions (see also Art. 77 GDPR); the competent supervisory authority is Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein, Holstenstraße 98, 24103 Kiel, Germany, Telephone: +49 431 9881200, Email: mail@datenschutzzentrum.de

In addition, the controller is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.

Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the controller's future processing of their data pursuant to Art. 6 Para. 1 lit. f) GDPR. In particular, an objection to data processing for the purpose of direct advertising is permissible.
If you wish to make use of your right of revocation or objection, an e-mail to datenschutz@luebeck-air.de is sufficient.

 

III. Information about the data processing

Your data processed when using our website will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations - also from security requirements such as § 7 German Aviation Security Act (LuftSiG) -  or unless otherwise stipulated below.

• Server data

For technical reasons, the following data sent by your internet browser to us or to our server provider will be collected, especially to ensure a secure and stable website: These server log files record the type and version of your browser, operating system, the website from which you came (referrer URL), the webpages on our site visited, the date and time of your visit, as well as the IP address from which you visited our site.

The data thus collected will be temporarily stored, but not in association with any other of your data.

The basis for this storage is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the improvement, stability, functionality, and security of our website.

The data will be deleted within no more than seven days, unless continued storage is required for evidentiary purposes. In which case, all or part of the data will be excluded from deletion until the investigation of the relevant incident is finally resolved..

• Cookies

a) Session Cookies

We use cookies on our website. Cookies are small text files or other storage technologies stored on your computer by your browser. These cookies process certain specific information about you, such as your browser, location data, or IP address.  

This processing makes our website more user-friendly, efficient, and secure, allowing us, for example, to display our website in different languages or to offer a shopping cart function.

The legal basis for such processing is Art. 6 Para. 1 lit. b) GDPR, insofar as these cookies are used to collect data to initiate or process contractual relationships.

If the processing does not serve to initiate or process a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Art. 6 Para. 1 lit. f) GDPR.

When you close your browser, these session cookies are deleted.

b) Third-party cookies

If necessary, our website may also use cookies from companies with whom we cooperate for the purpose of advertising, analyzing, or improving the features of our website.

Please refer to the following information for details, in particular for the legal basis and purpose of such third-party collection and processing of data collected through cookies.

• OpenStreetMap

For directions on our site, we use OpenStreetMap, a service of the OpenStreetMap Foundation, St John's Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom, hereinafter referred to as "OpenStreetMap".

When you access one of our Internet pages that includes the OpenStreetMap service, OpenStreetMap stores a cookie on your terminal device via your browser. This processes your user settings and user data for the purpose of displaying the page or guaranteeing the functionality of the OpenStreetMap service. Through this processing, OpenStreetMap can recognize the website from which your request has been sent and to which IP address the directions should be transmitted.

The legal basis for collecting and processing this information is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the optimization and economic operation of our site.

If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Further details can be found in the section about disabling cookies.

Vimeo offers further information about its data collection and processing as well your rights and your options for protecting your privacy at this link:

https://wiki.osmfoundation.org/wiki/Privacy_Policy.

c) Disabling cookies

You can refuse the use of cookies by changing the settings on your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support. Browser settings cannot prevent so-called flash cookies from being set. Instead, you will need to change the setting of your Flash player. The steps and measures required for this also depend on the Flash player you are using. If you have any questions, please use the help function or consult the documentation for your Flash player or contact its maker for support.

If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.

d) Right of objection

If you do not agree with this data processing by cookies, you can inform us at any time and object to the data processing free of charge. Your data will then no longer be processed. For this purpose, a so-called opt-out cookie is stored in your Internet browser, which means that no more data is collected about your visit to our website. Simply click on the button below [Hier einen Button einfügen mit dem nachstehenden Text und einer Verlinkung zu eine Opt-Out-Cookie: "I hereby object to the processing of my personal data by cookies on the website luebeck-air.de"].

 

• Flight booking

a) Collection of personal data

You have the possibility to book our flights via our website. We process the data you provide us with in the process to execute the contract of carriage concluded with you. In the input masks on our website, we indicate which information is mandatory for statutory or contractual requirements. This also applies to the creation of a Lübeck Air account for the purpose of booking a flight, which may be requested when booking a flight.

b) Purpose of processing and legal basis

The legal basis for processing in the context of the fulfilment of contractual obligations is Article 6 Para 1 b) GDPR. We process your data in particular for the following purposes:

• transmission of the booking confirmation (email),
• issue of the e-ticket and the invoice receipt,
• provision of flight-related information and booked services,
• handling of check-in from the invitation to waiting list processing and baggage handling.

Furthermore, we process your data to protect our legitimate interests on the legal basis of Art. 6 Para. 1 lit. f) GDPR for the following purposes:

• prevention and clarification of criminal offences (e.g. credit card misuse, identity fraud and the obtaining of benefits by fraudulent means),
• assertion of legal claims (including collection) and defence against legal disputes,
• ensuring safety (IT and aviation safety),
• management and further development of our business activities
• risk management,
• creation of statistics to improve offers and services (including the ticket number)..

The processing of your personal data is also based on legal obligations. The legal basis is Art. 6 Para. 1 lit. c) GDPR.

c) Duration of data storage

We delete the data with complete contract processing, but in doing so we must observe the storage periods under tax and commercial law as well as any security requirements such as those under § 7 of the German Aviation Security Act (LuftSiG). The duration of the data storage depends on the legal storage obligations and is usually 10 years.

 

d) Data transmission

In relation to the aforementioned data collection and processing and the respective legal basis (execution of the contract, in the legitimate interest or due to legal processing obligations), your data may be disclosed to the following categories of recipients:

• affiliated companies to which we transfer personal data for internal administrative purposes within the group of companies,
• vicarious agents (e.g. the service providers for ground handling at the departure and destination airports and other related supplementary services),
• other airlines which carry out carriage on behalf of Lübeck Air,
• other service providers (e.g. provision of the website, passenger enquiries and surveys or for compiling statistics, payment processing),
• public and government bodies and authorities (e.g. due to entry regulations or police and investigation activities)..

It may happen that personal data are transferred to third countries or to international organizations. For your protection and the protection of your personal data, appropriate guarantees are provided for such data transfers in accordance with and in compliance with the legal requirements.

 

• Contact

If you contact us via email or the contact form, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your inquiry; otherwise we will not be able to answer it in full or at all.

The legal basis for this data processing is Art. 6 Para. 1 lit. b) GDPR.

Your data will be deleted once we have fully answered your inquiry and there is no further legal obligation to store your data, such as if an order or contract resulted therefrom.

 

• User posts, comments, and ratings

We offer you the opportunity to post questions, answers, opinions, and ratings on our website, hereinafter referred to jointly as "posts." If you make use of this opportunity, we will process and publish your post, the date and time you submitted it, and any pseudonym you may have used.

The legal basis for this is Art. 6 Para. 1 lit. a) GDPR. You may revoke your prior consent under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent.

In addition, we will also process your IP address and email address. The IP address is processed because we might have a legitimate interest in taking or supporting further action if your post infringes the rights of third parties and/or is otherwise unlawful.

In this case, the legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in any legal defense we may have to mount.

 

• Online job applications / publication of job advertisements

We offer you the opportunity to apply for jobs with our company via our website. In the case of these digital applications, we collect your application data electronically in order to process your application.

The legal basis for this processing is §26 Para. 1 S. 1 BDSG in conjunction with Art. 88 Para. 1 GDPR.

If you are hired as a result of the application process, we will store the data you provide during the application process in your personnel file for the purpose of the usual organizational and administrative process, naturally in compliance with further legal obligations.

The legal basis for this processing is §26 Para. 1 S. 1 BDSG in conjunction with Art. 88 Para. 1 GDPR.

If we do not hire you, we will automatically delete the data submitted to us two months after the final decision is made. We will not delete the data, however, if we must store the data for legal reasons such as evidence of equal treatment of applicants, until any legal action is concluded, or four months.

In this case, the legal basis is Art. 6 Para. 1 lit. f) GDPR and §24 Para. 1 No. 2 BDSG. Our legitimate interest lies in any legal defense we may have to mount .

If you expressly consent to a longer storage of your data, e.g. for your inclusion in a database of applicants or interested parties, the data will be processed further on the basis of your consent. The legal basis is then Art. 6 Para. 1 lit. a) GDPR. You may withdraw your consent at any time with future effect per Art. 7 Para. 3 GDPR with future effect.

 

• Google Fonts

Our website uses Google Fonts to display external fonts. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: Google).

Through certification according to the EU-US Privacy Shield

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google guarantees that it will follow the EU's data protection regulations when processing data in the United States.

To enable the display of certain fonts on our website, a connection to the Google server in the USA is established whenever our website is accessed.

The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the optimization and economic operation of our site.

When you access our site, a connection to Google is established from which Google can identify the site from which your request has been sent and to which IP address the fonts are being transmitted for display.

Google offers detailed information at

https://adssettings.google.com/authenticated

https://policies.google.com/privacy

in particular on options for preventing the use of data.

 

• Facebook

To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Facebook platform.

On this social media platform, we are jointly responsible with Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland.

The data protection officer of Facebook can be reached via this contact form:

https://www.facebook.com/help/contact/540977946302970

We have defined the joint responsibility in an agreement regarding the respective obligations within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link:

https://www.facebook.com/legal/terms/page_controller_addendum

The legal basis for the processing of the resulting and subsequently disclosed personal data is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.

The legal basis may also be your consent per Art. 6 para. 1 lit. a GDPR granted to the platform operator. Per Art. 7 para. 3 GDPR, you may revoke this consent with the platform operator at any time with future effect.

When accessing our online presence on the Facebook platform, Facebook Ireland Ltd. as the operator of the platform in the EU will process your data (e.g. personal information, IP address, etc.).

This data of the user is used for statistical information on the use of our company presence on Facebook. Facebook Ireland Ltd. uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Facebook Ireland Ltd. can provide advertising both within and outside of Facebook based on your interests. If you are logged into Facebook at the time you access our site, Facebook Ireland Ltd. will also link this data to your user account.

If you contact us via Facebook, the personal data your provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.

Facebook Ireland Ltd. might also set cookies when processing your data.

If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Facebook may be fully usable.

Details on the processing activities, their suppression, and the deletion of the data processed by Facebook can be found in its privacy policy:

https://www.facebook.com/privacy/explanation

It cannot be excluded that the processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc., 1601 Willow Road, Menlo Park, California 94025.

Facebook Inc. has submitted to the EU-US Privacy Shield, thereby complying with the data protection requirements of the EU when processing data in the USA.

https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

 

• Instagram

To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Instagram platform.

On this social media platform, we are jointly responsible with Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.

The data protection officer of Instagram can be reached via this contact form:

https://www.facebook.com/help/contact/540977946302970

We have defined the joint responsibility in an agreement regarding the respective obligations within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link:

https://www.facebook.com/legal/terms/page_controller_addendum

The legal basis for the processing of the resulting and subsequently disclosed personal data is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.

The legal basis may also be your consent per Art. 6 para. 1 lit. a GDPR granted to the platform operator. Per Art. 7 para. 3 GDPR, you may revoke this consent with the platform operator at any time with future effect.

When accessing our online presence on the Instagram platform, Facebook Ireland Ltd. as the operator of the platform in the EU will process your data (e.g. personal information, IP address, etc.).

This data of the user is used for statistical information on the use of our company presence on Instagram. Facebook Ireland Ltd. uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Facebook Ireland Ltd. can provide advertising both within and outside of Instagram based on your interests. If you are logged into Instagram at the time you access our site, Facebook Ireland Ltd. will also link this data to your user account.

If you contact us via Instagram, the personal data your provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.

Facebook Ireland Ltd. might also set cookies when processing your data.

If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Instagram may be fully usable.

Details on the processing activities, their suppression, and the deletion of the data processed by Instagram can be found in its privacy policy:

https://help.instagram.com/519522125107875

It cannot be excluded that the processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc., 1601 Willow Road, Menlo Park, California 94025.

Facebook Inc. has submitted to the EU-US Privacy Shield, thereby complying with the data protection requirements of the EU when processing data in the USA.

https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

 

Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as Page views, length of stay, operating systems used and origin of the user. This data may be combined by Google in a profile that is assigned to the respective user or their device.

Google Analytics uses technologies that enable the user to be recognized for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there.

This analysis tool is used on the basis of Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a GDPR; the consent can be revoked at any time.

IP anonymization

We have activated the IP anonymization function on this website. As a result, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transmitted to the USA. The full IP address is only transmitted to a Google server in the USA and shortened there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser plugin

You can prevent Google from collecting and processing your data by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on handling user data on Google Analytics in Google's data protection declaration: https://support.google.com/analytics/answer/6004245?hl=de.

Order processing

We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Storage period

Data stored by Google at user and event level that are linked to cookies, user IDs (e.g. user ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) are anonymized after 14 months or deleted. You can find details on this at the following link: https://support.google.com/analytics/answer/7667196?hl=de

Google Analytics
This website uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how you use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymisation is activated on this website, Google will first shorten any IP address within member states of the European Union or in member states of the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The IP address transmitted by your browser within the operating scope of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google’s collection of data generated by cookies and related to your use of the website (including your IP address), and the processing of this data by Google, by downloading and installing the browser plugin available at the following link (http://tools.google.com/dlpage/gaoptout?hl=de). You can prevent data collection by Google Analytics by clicking on the following link, which will set an opt-out cookie to prevent the future collection of your data when you visit this website: Disable Google Analytics. For more information on terms of use and privacy, please visit http://www.google.com/analytics/terms/de.html or http://www.google.com/intl/de/analytics/privacyoverview.html. We would like to point out that on this website Google Analytics has been extended by the code "gat.anonymizeIp();" in order to guarantee an anonymised collection of IP addresses (so-called IP-Masking).

Facebook Pixel

This website uses the visitor action pixel of Facebook for conversion measurement. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected will also be transferred to the USA and other third countries.

In this way, the behavior of site visitors can be tracked after they have been redirected to the provider's website by clicking on a Facebook advertisement. As a result, the effectiveness of Facebook ads can be evaluated for statistical and market research purposes and future advertising measures can be optimized.

The data collected is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook Data Use Policy. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.

The use of Facebook pixels is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in effective advertising measures, including social media. If a corresponding consent has been requested (e.B. consent to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

Basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

In Facebook's privacy policy you will find further information on the protection of your privacy: https://de-de.facebook.com/about/privacy/.

You can also disable the Custom Audiences remarketing feature in the Ads Settings section of https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.

Wenn Sie kein Facebook Konto besitzen, können Sie nutzungsbasierte Werbung von Facebook auf der Website der European Interactive Digital Advertising Alliance deaktivieren: http://www.youronlinechoices.com/de/praferenzmanagement/.

Created on the basis of Model Data Protection Statement for Anwaltskanzlei Weiß & Partner

Status: This privacy policy is currently valid and has the status of January 2022.