What is personal data?

According to Art 4 No 1 of the General Data Protection Regulation (hereinafter called “GDPR”) personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data or an online identifier. Data that is impossible to use (or to use with only disproportionate effort) to establish personal information on you − through anonymization of the information, for example − is not classed as personal data.

Who is the controller?

Pro Sky AG (Schanzenstraße 6-20, Cologne, Germany) (hereinafter also “Pro Sky”, “we”, “us”) wishes to inform you below of how your personal data are processed within the context of our offerings.

Why do we process your data (purpose of the processing) and what is the legal basis?

We process personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR) and the German Data Protection Act (BDSG).

We process personal data to fulfil contractual obligations pursuant to Art. 6(1), Subparagraph 1(b) GDPR. In particular this includes

• booking a flight

• issuing and sending booking confirmations

• providing flight-related services booked by you and flight-related information, such as catering, inflight services and luggage services

• administering the check-in and boarding.

We process passenger data on the basis of the legal obligations pursuant to Art. 6(1), Subparagraph 1(c) GDPR:

If obliged to do so by law, we process personal data in order to meet duties of retention under commercial or tax law or to meet legal security requirements, like:

Data transmission to immigration authorities:

• Based on the airline passenger data agreement between the EU and the USA and the EU and Canada

• Based on the German Airline Passenger Data Act (FlugDaG)

• API* (Advance Passenger Information) - we transmit data to the extent that we are obliged to participate in international travel control activities

Data transmission to health authorities

Data transmission to payment service provider

Invoice issuance

We also process your data for the purposes of our legitimate interests pursuant to Art. 6(1), Subparagraph 1(f) GDPR:

• so that we can provide you with relevant information about your booked flight and travel destination

• for the purpose of preventing, investigating and prosecuting criminal offences, such as fraud, e.g. credit card or identity fraud, the use of fraudulent means to obtain special terms or fares

• to enforce legal claims, including debt collection and defence in the event of legal disputes

• for auditing purposes

• to safeguard the Pro Sky and airline’s IT security and operations

• to guarantee flight safety

• for the purpose of creating aviation statistics

• for the purpose of creating statistics to improve our products and services. In individual cases, we may create customer profiles for this purpose by processing reservation data; however, these profiles will be anonymized immediately and will not be used to analyze or predict any aspects relating to your personal preferences.

• To communicate with you, to the extent that an ongoing business relationship with you or your employer already exists, or it is intended to be established (business contacts).

• Data transmission to trade fair organizer for the provision of entrance ticket.

• payment service provider

We process your data based on your consent pursuant to Art. 6(1), Subparagraph. 1(a) GDPR for specific purposes, especially:

• for sending out newsletters with regular offers from Pro Sky and and partner companies

• for market research and customer surveys

• to support processes relating to usage of the website, with reminder features and live chats

• for analytical purposes so that we can optimise our offer for you.

Any consent given can be withdrawn at any time. Withdrawal of consent has effect for the future only and does not affect the lawfulness of data processed until the withdrawal.

Which personal data are you required to provide?

The input fields on our website forms were carefully created to request only the strictly necessary information, which are to be filled out on your part, so that we can provide you with the desired contract or service. If the input field is not strictly necessary, it will be marked as “ optional”

How long are your data stored?

Your personal data is erased as soon as it is no longer required for the purposes stated. However, if necessary, we must continue to store your data until the retention periods and deadlines expire, set by the legislator or supervisory authorities, which may arise from the German Commercial Code (Handelsgesetzbuch), Tax Code (Abgabenordnung) or Money Laundering Act (Geldwäschegesetz). These generally amount to six to ten years. We may also retain your data until the statutory limitation periods have expired (usually three years, but up to 30 years in some cases), provided that this is necessary for the establishment, exercise or defence of legal claims. After that, the relevant data are routinely erased.

Who receives your data?

In the context of the data processing above and the respective legal bases given (contract performance, legitimate interests, consent or processing obligations under law), your data may be passed on to the following categories of recipients:

• Pro Sky Group.

• vicarious agents, e.g. service providers for ground handling services and other additional related services

• airlines performing the carriage

• Trade Fair Organizers

• other service providers, e.g. for the provision of the website, newsletter dispatch, feedback handling, compiling of international aviation statistics

• state agencies and bodies, e.g. based on entry requirements or police activities and investigations.

In the process, personal data may be transmitted to third countries or international organisations. For your protection and the protection of your personal data, appropriate safeguards are provided for such data transmissions as per and in accordance with legal requirements.

If these transmissions do not have a legal basis or are carried out to a country, for which the EU Commission has not issued an adequacy decision, we use EU standard contractual clauses.

What are your data protection rights?

Pro Sky is committed to ensuring fair and transparent processing. That is why it is important to us that you can not only exercise your right to object but also to exercise the following rights where the respective legal requirements are satisfied:

• Right to information, Art. 15 of the GDPR

• Right to rectification, Art. 16 GDPR

• Right to deletion (right to be forgotten), Art. 17 GDPR

• Right to restrict processing, Art. 18 GDPR

• Right to data portability, Art. 20 GDPR

• Right to object, Art. 21 of the GDPR

To exercise your right, please contact us by email at marketing@pro-sky.com

In order to be able to process your request, as well as for identification purposes, please note that we will use your personal data in accordance with Art. 6 para. 1 (c) of the GDPR.

You also have the right to submit a complaint with the supervisory authority.

How can you withdraw your consent?

If you gave us your consent to processing your personal data, please note that you may withdraw this consent at any time.

If you have consented to receive our newsletter, you may withdraw this consent yourself using the Unsubscribe link in the newsletter.

In all other cases or if you have problems withdrawing your consent on this website, you can contact the data protection officer.

Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis – to perform a contract, for example.

What data do we process when you visit our website?

Our website uses cookies. Cookies are small text files placed by a web portal in the computer systems (computer, tablet or smartphone) of the users that visit it. Cookies may store personal data.

By using cookies, we are able to provide the you a more user-friendly services than would have been possible had the cookie not been set. By employing a cookie, the information and offers on our internet pages can be optimised for you. 

We differentiate between cookies that are absolutely necessary for the website’s technical features and optional cookies, you can chose when you access our webpage for the first time or later. You always can deactivate or restrict the transmission of cookies by changing the setting in your Internet browser. Furthermore, already placed cookies can always be deleted using the Internet browser or other software programs. This is possible in all commonly used Internet browsers. If you delete all cookies, this will also delete any opt-out cookies placed, so you will have to actively opt-out again

Please note that when you deactivate cookies, all the functions of our website may not be fully usable.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. 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. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB .

You can refuse the use of Google Analytics by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this website: Disable Google Analytics

Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html  or at https://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics code is supplemented by “gat._anonymizeIp();” to ensure an anonymized collection of IP addresses (so called IP-masking).

The use of Google Analytics is legally based on our legitimate interest to design and statistically evaluate our website. In this case your legitimate interests do not outweigh, Art. 6 Para 1 lit. f GDPR.