We are delighted that you have visited the world of Jettainer, including our Website, our web based ULD Management solution JettWare, and our mobile ULD Management tool JettApp. We are committed to transparency and integrity in processing your personal data. In processing personal data, we comply with requirements under data protection law, in particular the EU General Data Protection Regulation (“GDPR”) and the German Federal Data Protection Act (“BDSG”). 

In this Data Privacy Statement, we explain what information (including personal data) we process during your visit and use of our aforementioned offerings and which rights you have in relation to your personal data.
  
1.    Who is responsible for processing the data? 

The party responsible for processing personal data, or the controller, under data protection law is Jettainer GmbH, Am Prime Parc 17, 65479 Raunheim, Germany. Where the words “we” or “us” are used in this Data Privacy Statement, they refer to the above company. 
We have appointed the Data Protection Officer of the Lufthansa Group as our company’s Data Protection Officer. If you have any questions regarding the processing of your personal data, you can contact the Data Protection Officer at any time by post (FRA CJ/D, Airportring - LAC, 60546 Frankfurt) or e-mail (datenschutz@dlh.de).


2.    What principles do we observe? 

In compliance with requirements under data protection law, we process personal data only if we are permitted to do so under a statutory provision or you have given us your consent. 
On this Website we can also record items of information that, taken on their own, do not allow us to directly draw conclusions about your person. Nevertheless, this information may constitute “personal data” within the meaning of data protection law in certain cases, in particular if it is combined with other data. In addition, we may also record information on this Website that does not enable us to identify you directly or indirectly; this is the case, for example, with aggregated information on all users of this Website. 


3.    What data do we process? 

You can access our Website without directly providing personal data (such as your name, postal address or e-mail address). In this case, too, we have to process certain information to enable you to access our Website. Moreover, on this Website we use certain analytics methods and have integrated links to other Websites whose operators may process further (personal) data. 

1.    Log files: When you visit this Website, our web server automatically stores the domain name or IP address of the requesting computer system (usually your internet access provider), including the date, time and length of your visit, the sub-sites/URLs you visit, and information on the applications and devices you use to view our sites. 

2.    Cookies: Like many well-known companies, we use cookies or other tracking functions (“cookies”) to make our offering as user-friendly as possible. Most of the cookies we use are what are termed session cookies. They are automatically deleted when your visit is over. However, we also use persistent cookies, - also from third-party providers - if you allow us to do so, in order to make our Website more convenient for you to use or to improve our services and our Website by analyzing your use of our Website . We also distinguish between cookies that are absolutely necessary or essential for the technical functions of the Website, so-called "Essential Cookies," and so-called “Optional Cookies,” which in turn are divided into different categories, such as “comfort”, "statistics" or “marketing”. You will find more information about the cookies we (like to) use on our Website and the possibility to adjust your cookie settings at any time via the link to the “cookie settings” in the footer of our Website.

3.    Links to other Websites: Our Website contains links to other offerings. Please note that when you call the other offering, information (possibly including personal data) on your visit may be collected by the operator of the other offering. You can find more information in the data privacy statements of the operators of the offering. 

4.    Means of contact: On our Website, we point out various ways you can contact us. If you use one of these ways, we process the information we ask for and/or you give us in order to handle your inquiry. If necessary, this information may be stored for a longer period of time after completion of the processing for reasons of preservation of evidence.

5.  Matomo: We have included Matomo, a service of InnoCraft Limited, 150 Willis Street, Wellington 6011, New Zealand, on this website ("Matomo"). Matomo is an open source software tool for analyzing how visitors use our website. Among other things, we use the data and information obtained to evaluate the use of this website and to compile online reports that show the activities on our website. For these purposes, the service uses cookies to record, among other things, a pseudonymised code assigned to your browser (so-called user ID), from which third-party website you came to our site (so-called referrer URL), information about access time and location from which access originated, which parts of our website you visit and how often and for how long you viewed a certain part of our website. Your IP address is automatically shortened and therefore only recorded anonymously by Matomo. With the evaluated data and online reports, we gain insights into how our website is used. This allows us to customize and improve the website based on actual visitor usage and user needs.

6.    Registration and user account: On our Website we offer you the possibility of registering as a Jettware user, in particular so that you can use our ULD Management Services. Only employees, contact persons and representatives (jointly termed “Contact Person(s)”) of existing customers and business partners (jointly termed “Business Partner(s)”) can register. Please note that we do not permit registration by Contact Persons who are minors in our General Terms and Conditions or special terms and conditions for use of our e-services. During registration, we collect not only details of the Business Partner, but also personal data on the Contact Person as defined specifically in the registration mask. Obligatory information is indicated as such. We may ask you to enter the data collected during registration again (in particular so that you can be identified) and collect further personal data if you use certain content or features on our Website.


4.    For what purposes do we process your data and what is the legal basis for that? 

1.    Personal data that may be contained in the log files is processed to enable you to use our Website; that is done on the basis of Article 6 paragraph 1 point (f) GDPR so as to safeguard our legitimate interests in operating our Website. 

2.    The data collected using Essential Cookies and the pseudonymous user profiles are processed for the purposes of tailoring our Website to users’ needs on the basis of Article 6 paragraph 1 point (f) GDPR so as to safeguard our legitimate interests in the use of our Website. The data collected using Optional Cookies and the pseudonymous user profiles are processed for the purposes of analyzing the Website, advertising, and market research on the basis of your consent and Article 6 paragraph 1 point (a) GDPR.

3.    Personal data provided to us as part of an inquiry directed to us using the channels specified on the Website is processed to deal with the inquiry so as to safeguard our legitimate interests in conducting an existing business relationship or performing our other business activities on the basis of Article 6 paragraph 1 point (f) GDPR. 

4.    Personal data of our Business Partners’ Contact Persons or other natural persons (recipient of the consignment or recipient’s Contact Person) that is collected as part of registration or use of a user account and/or the e-services is processed so as to safeguard our legitimate interests in conducting existing business relationships on the basis of Article 6 paragraph 1 point (f) GDPR. 

5.    Data provided as part of registration as JettWare user is processed for the performance of a contract to which the data subject is acting as a Contact Person on the basis of  Article 6 paragraph 1 point (b) GDPR.
 
6.    We can also process the personal data collected in connection with the use of our Website to comply with legal obligations to which we are subject; this is done on the basis of Article 6 paragraph 1 point (c) GDPR. 

7.    Where necessary, we also process personal data above and beyond the above-mentioned purposes to safeguard further legitimate interests or the interests of third parties; this is done on the basis of Article 6 paragraph 1 point (f) GDPR.
Our legitimate interests include: 
a)    establishing legal claims and defending ourselves in legal disputes; 
b)    preventing and investigating criminal acts; and 
c)    controlling and further development of our business activities, including risk management and operation of our IT systems. 


5.    Do I have an obligation to provide data? 

The particulars required for registration are indicated as mandatory details in the relevant section of our Website (e.g. an online form); if you do not provide these mandatory details, we cannot enable you to use the feature in question. 
If we collect personal data from you above and beyond that, we notify you at the time whether the information has to be provided under the law or a contract or is necessary so that a contract can be concluded. We usually indicate information that is provided voluntarily and does not have to be furnished pursuant to one of the above obligations or is not required to conclude a contract. 


6.    Who receives personal data? 

In general, personal data is processed inside our company. Only specific departments/organizational units can access personal data, depending on its nature. They include in particular the specialist departments tasked with providing our digital offerings (e.g. Websites) or the described business processes, and our IT department. A role and authorization concept restricts access at our company to the functions and the scope required for the purpose for which the data is processed. 
We may also transfer personal data to third parties outside our company to the legally permissible extent. In particular, these external recipients may include 
•    affiliated companies in the Lufthansa Group to which we transfer personal data for internal administrative purposes and for the performance of central services (e.g. billing services); 
•    service providers whom we have engaged and who, on the basis of a separate contractual agreement, provide us with services that may also involve processing personal data, as well as the subcontractors our service providers engage with our consent; 
•    non-public and public bodies, where we are obliged to transfer your personal data pursuant to statutory obligations, 
•    recipients of a consignment we deliver for one of our Business Partners; the consignments may also contain personal data from you in individual cases if you have been named as the Contact Person in the provided consignment data; 
•    other Contact Persons at your organization if they are likewise registered to use our ULD management services; in this case, all Contact Persons within the organization of a Business Partner may be able to access details of all business transactions of that Business Partner (including information on your involvement in such a business transaction) using the ULD management services;
•    other Contact Persons at your organization or its customer airline(s) if they are asked to verify and approve your user account using the registration data provided by you.
•    furthermore, we may transfer further data to third parties within the scope of the use of cookies and tracking functions on our Website, according to the details set down in ourthe information contained in the “cookie settings”, you can access at any time via the link in the footer of our Website. 


7.    Is automated decision-making used? 

We do not use any automated decision-making (including profiling) within the meaning of Article 22 GDPR in connection with operation of our Website. If we use such methods in individual cases, we will notify you separately to the legally prescribed extent.  


8.    Is Personal data transferred to countries outside the EU/EEA? 

In most cases, personal data is processed within the EU or the European Economic Area. 
Since Jettainer operates globally and we also perform our services worldwide, we also transfer information to recipients in what are termed “third countries”. “Third countries” are countries outside the European Union or not party to the Agreement on the European Economic Area where it cannot be readily assumed that they have a level of data protection comparable to that in the European Union. Recipients in third countries may be, for example, service providers we engage (such as our ULD Control Desk) or the foreign offices of our own we run as part of our international presence. 
If the transferred information also includes personal data and we do not have a legal obligation to disclose such data, we ensure before transferring it that the necessary adequate level of data protection is ensured in the third country in question or at the recipient in the third country. That may be based in particular on an “adequacy decision” by the European Commission, in which an adequate level of data protection is ascertained for a specific third country as a whole. Alternatively, we can transfer data on the basis of EU standard contractual clauses agreed with a recipient. For information about the EU Standard Contract Terms, click here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en, and for information about the adequacy decisions click here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en#dataprotectionincountriesoutsidetheeu  


9.    For how long is personal data stored? 

In general, we store personal data according to article 17 GDPR only for as long as they are necessary for the purposes mentioned, or if we have legitimate interests in storing it and they are not overridden by your interests in your data no longer being stored. Subsequently, such data will be deleted in order to comply with the principle of data minimization. 

Even if we have no legitimate interests, we can continue to store your data if we are required to do so by law (such as to comply with retention obligations). We erase your personal data, also without any action on your part, as soon as we no longer need to know it in order to fulfill the purpose of processing or storage of it is otherwise legally impermissible. 

Personal data we have to store in order to comply with retention obligations is stored until the obligation to retain ends. If we store personal data solely to comply with retention obligations, it is usually blocked, meaning it can only be accessed when that is required for the purpose for which the data had to be retained. 

10.    What are your rights as an affected person? 

a)    Right of Objection according to Article 21 GDPR 
As a data subject you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning yourself which is based on point (e) or (f) of Article 6 (1), including profiling based on those provisions. In the event of such an objection, we will no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds to further process the personal data, outweighing your interests, rights and freedoms, or (ii) the processing is used for effective exercise or defense of legal rights. 
In case we process your personal data for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning yourself for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object processing for direct marketing purposes, the relevant personal data will no longer be processed for these purposes. 

b)    Withdrawal of consent
If you have given us your consent to process your personal data, we hereby inform you that you can withdraw this consent at any time, e.g. by clicking on the corresponding link in each of our newsletters or in our e-mailings or with regard to cookies, by selecting the appropriate boxes in the Cookie Settings, which you can access at any time via the link in the footer of our Website or by sending us a corresponding message by post, fax or e-mail via one of the contact channels mentioned in Section 1 of this Data Privacy Statement. You can also withdraw or modify your consent to the use of cookies at any time by clicking on this link.  In all other cases or if you have problems to withdraw your consent, you can also contact our Data Protection Officer, also mentioned in Section 1 of this Data Privacy Statement.
 
Please note that the consent you have withdrawn will only have effect for the future and has no influence on the lawfulness of processing based on consent before its withdrawal. In some cases, despite your withdrawal, we are entitled to process your personal data on a different legal basis - for example, to fulfil a contract.

c)    Additional Rights 
As an affected person, you also have the right to 
•    access the personal data stored on you (Article 15 GDPR); 
•    have incorrect data rectified and to have incomplete data completed (Article 16 GDPR); 
•    demand erasure of personal data (Article 17 GDPR); 
•    demand restriction of processing (Article 18 GDPR); and 
•    demand data portability (Article 20 GDPR), 

In order to exercise these rights you can contact us at any time contact by mail:  dataprotection@jettainer.com 

If you have questions relating to processing of data, you can also contact our Data Protection Officer, whose contact information you can also find in Section 1 of this Data Privacy Statement.

If you have questions relating to processing of data, you can also contact our Data Protection Officer. 

As a data subject you, also have the right to lodge a complaint with a supervisory authority responsible for data protection (Article 77 GDPR). 


11.    Changes to the Data Privacy Statement

Due to the further development of our Website and our offers or due to changed legal or official requirements, it may become necessary to change this Data Privacy Statement.

If this results in fundamental changes for you or if legal provisions make this necessary, we will inform you of such changes (with a corresponding note when you go to our Website).

You can access and print out the current Data Privacy Statement on our Website at any time.

Status: June 2021