Privacy Policy

In addition to being bound by strict German and European legislation concerning data privacy, Spairliners wishes to assure you of its strong commitment to the following principles, which in certain aspects go even further than the current legislation. Spairliners feels a strong need to observe a balance between offering personalized services to its customers and safeguarding the individual’s right to data privacy. In the event of any questions or problems concerning this Privacy Policy, please contact our data security officer.

Principles

Spairliners does not collect personally identifiable information through the Internet or otherwise unless you explicitly choose to provide this information. If Spairliners collects information, this will only be for clearly specified purposes.
When you choose to provide us with information, it is kept strictly confidential. We do not sell, share or in any way disclose the information obtained for specific purposes to third parties unless obliged to do so by law and/or legal proceedings (e.g., court orders).

The data our customers provide us with is discarded as soon as the original purpose is no longer relevant or the customer informs us that he/she desires the data to be discarded.
We make every effort to keep data given to us accurate and up to date, and we will process requests for updates quickly and reliably.
We make sure that our staff are trained to adhere to these standards. Our employees sign a statement of commitment to these principles.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Internet Links

We are aware that quite a few participating parties on the Internet do not adhere to these principles. We do not accept any responsibility for the behavior and practices of the third parties involved. Although we try to make sure that sites we link to adhere to the principles mentioned above, we are not responsible for the content and privacy policy employed by other Internet sites, carriers and ISPs.

Cookies, Tracking, and Web Analysis Tools

A cookie is a small element of data that can be exchanged between an Internet site and a client’s browser. It can be stored on either side to enable the Internet application to recognize the client on return. You can set your browser to notify you when you receive a cookie, and you may choose to accept the cookie or not. If you do not accept the cookie the corresponding Internet page cannot be accessed. If you accept the cookie, you can delete it from the file (cookies.txt) or from the directory (e.g.: ..\WINNT\cookies\…) after the session.

Social Plugins

Spairliners does not use social plugins.

Tracking tool: Google Analytics

We use Google Analytics as a tracking tool. Its functions are explained in the following paragraphs.

The use includes the Universal Analytics operating mode. This makes it possible to assign data, sessions, and interactions across multiple devices to a pseudonymous user ID and thus analyze a user’s activities across devices.

Google Analytics is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use Google Analytics with the additional function offered by Google to anonymize IP addresses. While doing so, Google already shortens IPs within the EU in most cases and only does so in the United States in exceptional cases, while always saving shortened IPs only. You may object to the collection or processing of your data by using the following link to download and install a browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en.

To prevent Universal Analytics from collecting data across different devices, you must opt-out on all systems used. To Disable Google Analytics on our website, click on this link to opt-out.

The legal basis for using it is our legitimate interests in accordance with Article 6(1)(f) of the GDPR for the purpose of enhancing the efficiency of our website and (direct) marketing.

Google Analytics gives us insights into the following data:

  • When the website was accessed (month, year, week, day, time of day)
  • What devices were used to access the website and what browser and operating system those devices use
  • What individual pages of the website are visited
  • Visitors’ regions and languages
  • Visitors’ click behavior or click paths, click frequency
  • Dwell times on the individual pages of the website
  • Most-clicked pages on the website
  • Where the website was accessed from (referrer)
  • How often the website or its individual pages were called
  • Whether and how visitors return to the website or its individual pages
  • You can obtain more information on this tracking tool at: https://analytics.google.com/analytics/web/

Duration of Data Storage

The data sent by us and linked to cookies, user-identifiers (e.g. User-IDs) or advertising-identifiers are automatically deleted after 14 months, the shortest possible option in the Google Analytics settings. Data whose retention period has been reached is automatically deleted once a month.

General Terms and Conditions

The information provided on this site is intended for Spairliners customers and for other interested persons and provides information of a general nature only. It is not intended to create any legal obligation of Spairliners.
Spairliners has taken great care to compile the information and to ensure that it is correct and complete. The information is updated at irregular intervals. As such information may be subject to rapid and recurrent changes, we would like to point out that despite all efforts, the information may occasionally be out of date, incorrect or incomplete. As a result, Spairliners provides this information “as is” and makes no assurance or warranty with regard to such information.
The website and its content are not intended for persons in jurisdictions that do not permit the distribution or the access to the content of this site. It is the responsibility of the user to comply with any such limitations before accessing this site.

 

General Data Protection Regulation (GDPR)

The information provided on this site is intended for Spairliners customers and for other interested persons and provides information of a general nature only. It is not intended to create any legal obligation of Spairliners.
Spairliners has taken great care to compile the information and to ensure that it is correct and complete. The information is updated at irregular intervals. As such information may be subject to rapid and recurrent changes, we would like to point out that despite all efforts, the information may occasionally be out of date, incorrect or incomplete. As a result, Spairliners provides this information “as is” and makes no assurance or warranty with regard to such information.
The website and its content are not intended for persons in jurisdictions that do not permit the distribution or the access to the content of this site. It is the responsibility of the user to comply with any such limitations before accessing this site.

Data Collection

The information provided on this site is intended for Spairliners customers and for other interested persons and provides information of a general nature only. It is not intended to create any legal obligation of Spairliners.
Spairliners has taken great care to compile the information and to ensure that it is correct and complete. The information is updated at irregular intervals. As such information may be subject to rapid and recurrent changes, we would like to point out that despite all efforts, the information may occasionally be out of date, incorrect or incomplete. As a result, Spairliners provides this information “as is” and makes no assurance or warranty with regard to such information.
The website and its content are not intended for persons in jurisdictions that do not permit the distribution or the access to the content of this site. It is the responsibility of the user to comply with any such limitations before accessing this site.

Use of Data

When a visitor provides personal information to us, we only use it for the purposes for which it was provided to us. Our website spairliners.com does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.
As per Recital 63 GDPR, a data subject should have the right of access to personal data which have been collected concerning him or her, and to exercise that right easily and at reasonable intervals, in order to be aware of, and verify the lawfulness of the processing. The party responsible for the data protection is required to make available on request the data defined under Art. 4 (1) GDPR in a suitable manner. We readily comply with these obligations without the need for an individual application on your part. If you require information on your personal data, please send an email to humanresources@spairliners.com.

Duration of the Data Processing

Your personal data are not kept longer than needed for the personal data processing purpose of the processing operation. After the processing operation, your personal data will be deleted. It may happen that personal data are kept for the time in which claims can be asserted against Spairliners (legal limitation period of three to thirty years). In addition, the personal data will be stored if and as long as Spairliners is legally obliged to do so. Corresponding duties of proof and retention arise, amongst other, from the Commercial Code, the Tax Code and the Money Laundering Act. The storage periods are thereafter up to ten years.

According to Art. 21 GDPR (right to object) you have the right to object against the processing of personal data concerning you at any time, for reasons arising from any particular situation; this also applies to profiling based on these provisions. The controller will then no longer process the concerning personal data unless he/she can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is intended to assert, exercise or defend legal claims. If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58 / EC, you have the option, in the context of the use of information society services, of exercising your right to object through automated procedures that use technical specifications.

The legal basis for the temporary storage of data and log files is Article 6(1)(f) of the EU General Data Protection Regulation (GDPR)

Spairliners does not use your personal data for profiling or direct marketing purposes.

 

Disclosure of Personal Data to Third Parties

In order to offer you our products and services based on our contractual obligations or our legitimate interests, it may happen that we share your personal data with third parties within or outside the Lufthansa Group. These recipients can be categorized as follows:

· Contractors
· Freight Forwarding
· IT
· Providers and contractors of Ground Handling Services
· Government agencies and authorities
It may happen that personal data are transmitted to third countries or to international organizations. For your protection and the protection of your personal data suitable guarantees are provided for such data transfers in accordance with the legal requirements (in particular application of EU standard contractual clauses) or there is an adequacy decision issued by the EU Commission -Art. 45 GDPR (Transfers on the basis pf am adequacy decision).

Data Breach

If you discover personal data-related information that you consider a data breach, please send an e-mail to humanresources@spairliners.com immediately and we will address this topic with the highest priority.

 

Rights of Data Subjects

Spairliners GmbH is committed to the fair and transparent processing of data. We, therefore, believe it to be important that data subjects not only have the right to object but can also exercise the following rights if the relevant legal requirements are fulfilled:

  • Right to access personal data and obtain information (Article 15 of the GDPR)
    • Right to rectification (Article 16 of the GDPR)
    • Right to erasure (“right to be forgotten”) (Article 17 of the GDPR)
    • Right to a restriction of processing (Article 18 of the GDPR)
    • Right to data portability (Article 20 of the GDPR)

Please note: We do not transfer your data outside the EU. That is the right to data portability does not apply for Spairliners.

You can contact humanresources@spairliners.com by e-mail to exercise your rights. To handle your request and for the purpose of identification, we note that we will process your personal data in accordance with Article 6(1)(c) of the GDPR.

You also have the right to lodge a complaint with a supervisory authority. The supervisory authority responsible for Lufthansa Technik AG is:

The Hamburg Commissioner for Data Protection and Freedom of Information
(Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit)

Kurt-Schumacher-Allee 4

20097 Hamburg

Phone: +49 40 42854-4040
Fax: +49 40 42854-4000
E-mail: Mailbox@datenschutz.hamburg.de

 

Consent

We hereby want to inform you that you can revoke consent to the processing of your personal data at any time.
If you have given consent to this website, please visit the page where you originally submitted your consent or send an email to humanresources@spairliners.com.

Disclaimer and Limitations of this Privacy Policy

These privacy notices only deal with the processing of the website https://www.spairliners.com/ and the customer portal https://www.spairliners.com/customerportal.

Other websites are not covered by this privacy policy and should provide their own specific privacy notices.

If you have any further questions regarding this topic, please contact our data protection commissioner: Dr. Kirchberg-Lennartz (datenschutz@dlh.de).

 

 

COMPLIANCE

 

Statement of Spairliners Management Board

As a globally active company in the Maintenance-, Repair- and Overhaul industry (MRO) operating in various business fields and as part of the Air France KLM and Lufthansa Technik Group, Spairliners shares substantial responsibility for lawful behavior and fair competition in the relevant markets. Our goal is a sustainable economic success. Compliance with applicable laws forms the basis for all conduct of Spairliners Employees. The Spairliners Compliance Program provides a binding framework for all Spairliners employees and represents the clear and unmistakable commitment of the Management Board to comply with all applicable national and international laws, regulations, and guidelines. We are aware that any violation of applicable laws poses an extraordinary risk to Spairliners, to the Air France-KLM and Lufthansa Technik Group as a whole and to every one of us as an individual and is therefore unacceptable. We are all called upon to actively participate in implementing the Spairliners Compliance Program in our daily work and in our respective areas of responsibility, in order to prevent any harm from any individual and from our company.

 

Spairliners Compliance Guidelines

 

Integrity Compliance

The Integrity Compliance Guidelines establish general principles for anti-corruption measures and provides a framework for employees of Spairliners regarding the acceptance and granting of benefits, invitations and gifts. An invitation to events is a special form of a benefit and a guideline is in place that provides a framework for employees of Spairliners for invitations of third parties to events, either organized by Spairliners or to external events. Spairliners gives guidance to Spairliners employees on the provision of presents and gifts, inviting third parties to lunches and dinners and any other benefits Spairliners employees wish to provide to an external party. Also, regulations on Conflict of Interest are given to Spairliners employees, which have to be followed when they are offered any benefits, e.g. invitations to events or meals, gifts or any other benefits. Furthermore, any other potential conflict of interest such as private relationships with business partners is covered in this guideline. The Donations, Sponsorships and Memberships Guideline defines measures in order to avoid that no payments are used to influence any decisions by business partners or public officials.

 

Competition Compliance

The Competition Compliance Guideline familiarizes employees of Spairliners with antitrust and competition laws and regulations.

 

Ombudsman system

Spairliners follows the Ombudsman system of Lufthansa Technik Group. The Ombudsman is a freelance attorney who is not an employee of the Lufthansa Group. As a neutral, independent contact, the Ombudsman takes complaints in writing or by telephone and provides them to the Corporate Compliance Office in an anonymized form, if this is what the complainant wishes. The identity of the complainant is protected by the attorney-client privilege. Moreover, the Lufthansa Group has contractually agreed not to request access to any legally privileged information and to be informed of the complainant’s name only following his/her express consent.

Contact Ombudsman