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Page Name: Privacy and Security

Delta Air Lines, Inc.


PRIVACY POLICY

--------------------------------------------------------------------------------

Date effective: September 2024

1. This Privacy Policy


All information described in this Privacy Policy is processed by Delta Air
Lines, Inc. ("Delta", "we", "us", or "our") as data controller. This Privacy
Policy describes our practices related to the use, storage, and disclosure of
personal information we collect from or about you when you interact with us in
the course of our providing commercial air travel services, ancillary services,
or other services provided by us or by others acting on our behalf, including
when you use our website Delta.com ("Website") or our Fly Delta App ("App").
This Privacy Policy also describes our processing of the personal data of
individuals representing our business customers and suppliers.  The manner in
which we process information depends on the type of information and purpose for
processing and may include collection, organization, storage, alteration,
retrieval, consultation, disclosure, restriction, erasure, or destruction.

Delta reserves the right to modify this Privacy Policy at any time and without
prior notice. We will post any changes to our Website. This Privacy Policy is
not a contract and does not create any contractual rights or obligations.

Expand All Collapse All
2. How to Contact Us

Delta has a Privacy Team, including a Data Protection Officer, that is dedicated
to protecting your privacy. If you have any questions or comments regarding this
Privacy Policy or any complaints about our adherence to it, please contact our
Data Protection Officer, Renee Lopez-Pineda, at Privacy@delta.com or contact
our Customer Care Center by telephone or mail. We adhere to applicable
notification requirements and reporting obligations to supervising authorities
and/or data subjects regarding violations of this Privacy Policy as required by
law.  The substance and time frames applicable to these remedies are set forth
in applicable laws.

Additional remedies available in the event of a perceived violation of your
privacy rights are discussed in sections 9.7 and section 12 regarding
information security safeguards and data breach notification procedures.

3. How Does Delta Collect & Receive Your Information?

3.1 We collect information from you

We may collect and receive information from you, including when you:

 * use or access our Website or App, such as when you enter information during
   the course of a booking, even if you do not complete the booking;
 * register, create, or modify an online or in-app account with us, including
   your SkyMiles Partners account and promotional partners account, or any
   account to use our online corporate travel tool(s), communicate with us by
   email, including when you email us at Privacy@delta.com, telephone, in
   writing, through our customer services pages, or social media;
   
   
   * Our SkyMiles Partners are hotel, car rental, shopping, dining, vacation,
     and other businesses with whom you can earn, transfer, or redeem miles in
     the SkyMiles Program or otherwise qualify for discounts or benefits in
     connection with SkyMiles membership or Medallion Status. Our promotional
     partners are businesses with whom you may be offered a discount or benefit
     as a result of your transactions with Delta.
 * use any of our services, including when you travel with us, use airports
   where we operate, or use any facilities, such as Delta Sky Club lounge
   facilities, within those airports;
 * through cookies and other tracking technologies on our Website and App (see
   section 6 below); and
 * are associated to a company we do business with

3.2 Automatic access and data collection from our App

Our App may access certain device information and/or components automatically.

3.3 We collect information from other sources

We may receive your personal information from other airlines, and from travel
agencies and your employer or company in connection with your travel booking.

We may also receive your personal information from SkyMiles Partners and
promotional partners in connection with our SkyMiles Program.

Our suppliers and other businesses we deal with provide us personal information
of their representatives.

This Privacy Policy applies to information we receive from those other sources,
as well as to information we collect from you or generate about you. Delta is
committed to limiting the information collected to what is necessary for the
purposes for which the information is collected.

4. How Delta Uses Your Data

4.1 INFORMATION ABOUT YOU AND HOW WE USE IT

This section describes what personal information we collect about you, the
purposes for which we use it, and the legal basis under applicable law pursuant
to which we process it. We may also use your personal information for other
purposes if they are reasonably expected or incidental to those described in
this Privacy Policy. Please also see section 4.2 regarding information collected
through our App, and section 4.6 regarding our use of sensitive types of
information.

4.1.A

Information related to a flight booking or purchase of our products or
services, whether provided on line, over the phone, in person, at an airport
kiosk or self-service device, in flight, or otherwise, and whether bought
privately or through your employer or company including:

 * your name and title;
 * your national ID, in certain circumstances;
 * your contact details, such as postal address, telephone numbers, and email
   address;
 * your flight, luggage, boarding and other ticketing information, such as bag
   tag tracking number and luggage screening information, including X-ray images
   of checked luggage;
 * special assistance requests and preferences;
 * your billing and transaction information such as credit/debit card type and
   number(s), corporate forms of payment, and related data including associated
   billing address, and expiration date(s);
 * emergency contact(s);
 * seating preferences, medical needs, and dietary requests;
 * flight, car, and hotel preferences;
 * travel companions’ personal  information;
 * information about who is meeting or dropping you off;
 * your order for other services, such as cargo, animal services, and inflight
   services such as upgrades, beverages/food, and goods;
 * any employer or company information associated with your booking;
 * your reason for travel.

We use this information to:

 * provide you with your flight and other products and services;
 * provide assistance with bookings and seat assignments including where
   relevant for our corporate travel program customers, in cooperation with
   their corporate travel managers;
 * confirm your travel arrangements and remind you about incomplete bookings;
 * take your payment and make any refunds or credits and send any confirmations;
 * send you service communications, such as notifications of flight schedule
   changes, and check-in opening;
 * manage and administer our services and business, including performing our
   record-keeping requirements;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical);
 * confirm your identity and to prevent fraud;
 * improve our products and services, including through statistical analysis and
   research for program development;
 * send you marketing communications, offers, and invitations to events, which
   may be based on our segmentation and modelling of your personal information;
 * provide you with assistance in an emergency, including communicating with
   your emergency contacts;
 * share it with other airlines for the purposes of your itinerary or re-booking
   you if there is a travel disruption;
 * share it with our SkyMiles Partners and promotional partners for the purpose
   of their providing services to you; 
 * share it with authorized government agencies and as otherwise described
   in section 7.
 * share it for luggage security screening to enable you to travel within and
   between countries.
 * tailor our products and services for you, including anticipating your likely
   preferences based on information concerning your previous travel with us,
   previous transactions, or communications with us, any of which we may combine
   with other information we have about you, and which may be based on our
   segmentation and modelling of your personal information.

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent, for example, to us using information related to your
   health and dietary requirements, certain credit card information, or
   information to send you marketing communications;
 * it is necessary to protect your or a third party’s vital interests or to
   respond to a public health incident;
 * it is necessary to act in the public interest;
 * it is necessary to comply with applicable law and regulations, such as those
   related to flight operations, identity verification, and emergencies;
 * the information is publicly available;
 * we have a legitimate business interest, for example, in assisting you with
   making and managing your bookings with us, managing and administering our
   business and protecting it from fraud, improving and promoting our service
   and better understanding how customers use it, ensuring that our technical
   systems operate properly, protecting against risks to customers and aircraft,
   streamlining customs clearance processes for our customers, enabling Delta to
   support public health authorities’ efforts to inhibit the spread of COVID-19
   or other global pandemic symptoms, and ensuring the health and safety of
   customers traveling on Delta flights, and complying with applicable law and
   regulations;
 * we and third party airlines have a legitimate business interest in making and
   operating connections between multiple flights and expediting baggage
   clearance across international borders; or
 * we and our SkyMiles Partners, promotional partners and other businesses that
   are providing services that you request have a legitimate business interest
   in using the information to provide their services.

4.1.B

Customer identification information, including:

 * Secure Flight Passenger Data, such as your government issued ID; your full
   name; your contact details, such as postal address (or temporary address in
   the U.S. for non-U.S. customers); telephone numbers; email address; date of
   birth, gender; Known Traveler Number; and Redress Number;
 * Advance Passenger Information such as passport or other travel document
   number (including machine-readable information), nationality, issue date and
   location, expiry date, and country of residence;
 * information from the Department of Homeland Security or similar authorities
   responsible for security in other countries, if traveling from certain
   airports;
 * biometric information (such as finger, face, voice, or iris).

We use this information to:

 * verify and authenticate your identity; 
 * undertake security screening to enable you to travel within and between
   countries, as required by most governments; 
 * comply with legal and regulatory requirements;
 * confirm your identity at check-in, bag check location, security checkpoints,
   and when boarding the aircraft;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical);
 * share it with governments and as otherwise described in section 7;
 * provide you with your flight and other products and services;
 * send you service communications, such as expired or expiring passport.

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent, for example, to us using information related to your
   passport (beyond what is necessary for us to provide your flight), biometric
   information, or information to send you marketing communications;
 * it is necessary to protect your or a third party’s vital interests, or to
   respond to a public health incident;
 * it is necessary to act in the public interest, such as protecting against
   risks to customer and public health, customer and aircraft safety, and
   unlawful cross-border activities;
 * it is necessary to comply with applicable law and regulations, such as those
   related to flight operations, identity verification, and emergencies;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in protecting the
   security of your SkyMiles account and your travel reservations, ensuring that
   our technical systems operate properly, enabling Delta to support public
   health authorities’ efforts to inhibit the spread of COVID-19 or other global
   pandemic symptoms, ensuring the health and safety of customers traveling on
   Delta flights, and complying with applicable law and regulations.

4.1.C

Information related to your membership in our Delta Sky Club, the SkyMiles
Program or other account, or activities with our SkyMiles Partners and
promotional partners, including:

 * your name and contact details;
 * your SkyMiles status;
 * your SkyMiles account number;
 * your transactions and SkyMiles Program activity;
 * your choice of SkyMiles benefits;
 * your flight information including any travel group to which you are assigned;
 * your membership information for SkyMiles Partners or other account and
   promotional partners loyalty programs;
 * your employer or company details, your role, use of corporate forms of
   payment, and other information submitted through our online corporate travel
   tool(s), where you agree to associate your SkyMiles Program account with your
   employer’s or corporate business SkyBonus/SkyMiles for Business or other
   travel program
 * your date of birth; 
 * your gender;
 * your user ID, password and log-in credentials when using our online corporate
   travel tool(s) and access your accounts with us;
 * your digital image, if you consent to its collection in connection with
   access to our lounges.

We use this information to:

 * provide you with services related to your SkyMiles Program membership and
   activity with SkyMiles Partners, or promotional partners, if applicable,
   including mileage tracking;
 *  tailor our products and services for you, including anticipating your likely
   preferences based on information concerning your previous travel with us,
   previous transactions, or communications with us, any of which we may combine
   with other information we have about you, and which may be based on our
   segmentation and modelling of your personal information;
 * improve our products and services, including through statistical analysis,
   segmentation, and research for program development;
 * manage and administer our Delta Sky Clubs or the SkyMiles Program and for our
   related record-keeping requirements;
 * associate ·      your SkyMiles Program account with your employer’s or
   corporate business SkyBonus/SkyMiles for Business or other travel program to
   enable you to earn SkyMiles on your business travel, enable your employer or
   company to earn any business bonuses; enable your employer or company to
   administer and allocate your expenses, ticket, and other travel payments and
   procure travel assistance; and to otherwise operate that business account;
 * send you information about our products and services;
 * send you marketing communications, offers, and invitations to events, which
   may be based on segmentation and modelling of your personal information;
 * recognize your loyalty to the SkyMiles Program;
 * share your information with SkyMiles Partners and promotional partners as
   mentioned in section 7;
 *  verify and authenticate your identity to prevent fraud ; and
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical).

We use this information because:

 * it is necessary to enter into or to perform a contract with you relating to
   SkyMiles Program membership;
 * you have given consent, for example, to us using information to personalize
   your in-flight experience, using your digital image to grant you lounge
   access, or using information to send you marketing communications;
 * it is necessary to comply with applicable law and regulations;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in improving our
   service, personalizing it for our customers, and better understanding how
   customers use it, managing and administering our business and protecting it
   from fraud, ensuring that our technical systems operate properly, promoting
   and developing our business, and complying with applicable law and
   regulations.

4.1.D

Information related to your preferences and personal and professional interests,
and your opinions of our services,including:

 *  information about your Internet activity;
   
 * your survey responses;
   
 * your responses to our marketing efforts;
 * your demographics;
 * your contact preferences;
 *  your experience with our products and services.

We use this information to:

 *  provide our products and services to you;
 * tailor our products and services for you based on this information alone and
   in combination with other information we have about you;
 *  improve our products and services, including through statistical analysis
   and research for program development;
 *  maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical):
 * send you marketing communications, offers, and invitations to events, which
   may be based on segmentation and modelling of your personal information;
 *  send you online messages about products and services provided by us or our
   SkyMiles Partners, promotional partners, and other third parties that may be
   of interest to you.

We use this information because:

 * it is necessary to enter into or to perform a contract with you;
 * you have given consent, for example, to us using information to send you
   marketing communications;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in enabling you to
   manage your preferences and account details, improving our service,
   personalizing it for our customers, and better understanding how customers
   use it, ensuring that our technical systems operate properly, and promoting
   and developing our business.  

4.1.E

Information from your use of our Website or App including corporate travel
online tool(s) accessed through them, including:

 * your Internet service provider;
 * your browser type;
 * your operating system;
 * pages you access on our Website or App; 
 * the date and time of your access to our Website or App;
 * your device type;
 * the IP address or unique identifier of your device;
 * your location, established from GPS or network based features;
 * feedback you provide to us;
 *  your log-in credentials, if you have a SkyMiles or other account with us;
 * your online transactions with us;
 * your role or registration when using our corporate travel online tool(s).

We use this information to:

 * operate and administer our Website and App;
 * provide our products and services to you.  In the case of services provided
   through the App, these will be only the services you have chosen within the
   App, as further described in section 4.2;
 * improve our products and services, including through statistical analysis and
   research for program development;
 * send you messages and offers, about products and services provided by us or
   our SkyMiles Partners, promotional partners and other third parties that may
   be of interest to you, which may be based on your online behavior combined
   with other information we have about you and/or segmentation and modelling of
   your personal information;
 * tailor products and services for you, based or your browsing history on our
   Website, and use of the App, and combining this information with other
   information we have about you;
 * identify issues with our Website and App and users' experience of them;
 * monitor the way our Website and App are used;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical);
 * support your use of location-based tools, such as airport directions and map
   views, city code search, displaying local Delta Sky Clubs, and locating
   parking spaces;
   
 * send you information about services in your location which may be of
   interest;
 * administer your online account, if you have one;
 * recognize your role when administering our corporate travel program to
   generate appropriate training, support and promotional content within the
   tool or by email.

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent, for example, to us using information to send you
   marketing communications;
 * it is necessary to protect your or a third party’s vital interests, or to
   respond to a public health incident;
 * it is necessary to act in the public interest;
 * it is necessary to comply with applicable law and regulations;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in understanding how our
   Website and App are accessed, how they are used, any security issues
   affecting their operation, and any problems users have with the Website or
   App across multiple devices, improving our service and better understanding
   how customers use it, providing you with information relevant to your travel
   with us, ensuring that our technical systems operate properly, promoting our
   products and services and those of third parties, and in personalizing the
   information that our Website or App sends to you about these things, and
   complying with applicable law and regulations.

4.1.F

Information from your communications with us and our staff, including:

 * interactions in person on board our flights, or with ground staff;
 * emails, letters, online "chats", surveys, and telephone calls with our staff
   including our customer service teams;
 * via social media.

We use this information to:

 * deal with any issues and concerns;
 * provide our products and services to you;
 * personalize our services;
 * manage and administer our services and business and for our record-keeping
   requirements;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical);
 * improve our products and services, including through research for program
   development;
 * send you marketing communications, offers, and invitations to events, which
   may be based on segmentation and modelling of your personal information;
 * monitor communications for staff training, and quality checking purposes.

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent, such as in the case of information used to send you
   marketing communications;
 * it is necessary to protect your or a third party’s vital interests, or to
   respond to a public health incident;
 * it is necessary to act in the public interest;
 * it is necessary to comply with applicable law and regulations, such as those
   related to flight operations, identity verification, and emergencies;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in managing and
   administering our business and our relationship with you, ensuring that our
   technical systems operate properly, improving and developing our products and
   services, promoting and developing our business, and complying with
   applicable law and regulations.

4.1.G

Information relating to travel and aircraft emergencies, including:

 * your involvement in medical incidents affecting you and others during your
   travel with us;
 * professional information about individuals involved in your care;
   
 * your designated emergency contact.

We use this information to:

 * assist you and your family members if there is an emergency;
 * provide you with your program benefits;
 * provide you with appropriate and timely communications;
 * comply with legal and regulatory requirements;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical).

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent;
 * it is necessary to protect your or a third party’s vital interests, or to
   respond to a public health incident;
 * it is necessary to act in the public interest;
 * it is necessary to comply with applicable law and regulations, such as those
   related to flight operations, identity verification, and emergencies;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in ensuring that our
   technical systems operate properly, complying with applicable legal and
   regulatory requirements, and complying with applicable law and regulations.

4.1.H

Information we receive about you from other sources, including:

 * from SkyMiles Partners or other account, promotional partners, your SkyMiles
   Program activity and redemptions;
 * from other airlines, your and your fellow travelers' Passenger Name Record
   containing your names and itineraries;
 * from travel agencies;
 * from your employer;
 * demographic information from public records and third parties;
 * from financial institutions and credit checking agencies.

We use this information to:

 * administer your SkyMiles Program membership and rewards;
 * administer your Delta Sky Club membership;
 * provide you with flights;
   
 * manage and administer our services and business and for our record-keeping
   requirements;
 * combine it with other information for statistical research and marketing
   purposes;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical);
 * develop and promote our products and services;
 * check for and receive payment approval.

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent, for example, to us using information to send you
   marketing communications;
 * it is necessary to protect your or a third party’s vital interests, or to
   respond to a public health incident;
 * it is necessary to act in the public interest;
 * it is necessary to comply with applicable law and regulations, such as those
   related to flight operations, identity verification, and emergencies;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in improving and
   developing our products and services, performing our contract with your
   employer, ensuring the health and safety of customers traveling on Delta
   flights, ensuring that our technical systems operate properly, and complying
   with applicable law and regulations.

4.1.I

Business information of travelers on corporate accounts and of representatives
of suppliers, customers, and other businesses (including for cargo) we deal
with, including:

 * name, role and personal contact details at the company and personal
   information in communications with you;
 * corporate contact, and employer or affiliation (e.g., employer name, title,
   contact details, and contract information);
 * user ID, password and log-in credentials when using our corporate travel
   online tool(s).

We use this information to:

 * conduct our business dealings with our suppliers, customers, partners, and
   other businesses including for sales and purchases, and enabling use of our
   corporate travel online tool(s);
 * tailor our products and services for you based on this information alone and
   in combination with other information we have about you;
 * administer your company’s SkyBonus/SkyMiles for Business and other corporate
   travel benefits;
 * send you or your company marketing communications, offers, and invitations to
   events, which may be based on segmentation and modelling of your personal
   information;
 * recognize your role when administering our corporate traveler program to
   generate appropriate training, support and promotional content within the
   tool or by email;
 * maintain the operational availability and reliability of our IT systems with
   infrastructure backups and testing (which may use a copy of live data where
   test data is not practical).

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent, for example, to us using information to send you
   marketing communications;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in performing our
   contracts with our corporate customers, suppliers and other business,
   developing our business with our corporate customers, and ensuring that our
   technical systems operate properly.

4.1.J

Information required by public health authorities or other government agencies
or collected to demonstrate fitness to fly, including:


 * contact information, such as name, nationality, country of residence,
   originating address, destination address, telephone, and email;
 * information regarding the presence or absence of possible COVID-19 or other
   global pandemic symptoms;
 * information regarding potential exposure to COVID-19 or other global
   pandemic; 
 * information collected by our ground or reservations staff pursuant to
   directives by public health organizations or other government agencies.

We use this information to:

 * comply with legal and regulatory requirements; 
 * determine your fitness to travel consistent with applicable government
   regulations and guidelines.

We use this information because:

 * it is necessary to enter into or to perform a contract with you to provide
   flights or other products or services;
 * you have given consent;
 * it is necessary to protect your or a third party’s vital interests, or to
   respond to a public health incident;
 * it is necessary to act in the public interest;
 * it is necessary to comply with applicable law and regulations, such as those
   related to public health;
 * the information is publicly available; or
 * we have a legitimate business interest, for example, in ensuring the health
   and safety of customers traveling on Delta flights, and complying with
   applicable law and regulations.

We only base our use of personal data on our legitimate interests when we
consider that our legitimate interest is not overridden by the individual's
interests or rights in the data.

As used in this Privacy Policy, “consent” means any statement or clear
affirmative action by which you agree to the processing of personal data for a
specific purpose. Please note that where you have provided your consent to us
for processing your information, you can withdraw this at any time as described
in section 8.

4.2. INFORMATION COLLECTED THROUGH OUR APP

Delta may collect and receive personal information from the App users through
the Software Development Tools (SDKs) deployed on the Fly Delta App. Depending
on the SDK, the type of personal information collected and received via the SDKs
may include, without limitation, the App user’s name, email address, phone
number, mailing address, SkyMiles number, credit card information (to the extent
a credit card transaction is being made through the App), customer flight
information, App usage metrics, and device information such as IP address. Delta
may use such information to verify and authorize credit card transactions, to
receive feedback about the App and services, and to track and analyze usage of
the App. 

Please find below the current list of the Software Development Tools (SDKs)
deployed on the Fly Delta App. Delta may update this list of SDKs from time to
time if services provided by Delta change.

List of the SDKs deployed on the Fly Delta App as of April 1, 2022: 

 * Adobe Marketing Cloud + branch.io plugin 
 * Cardinal Commerce
 * ForeSee
 * American Express

We use push notification tokens in the App to send notifications to your mobile
device with updates for flight times, gate changes, and flight cancellations.
The App will activate your camera if you choose to take a picture for a parking
reminder, and will store the photo for you to look at later. If you choose, the
App can access your device calendar to save itinerary information in your
personal schedule. It can also bring up your default e-mail program, so you can
send notes and reminders while traveling.

At times, we may promote the App via internet advertising on external websites.
If you click on these advertisements and navigate directly to a third party
application or other platform, information such as your phone’s device
identification number may be sent to the advertising network, so that they and
we may track the effectiveness of our advertising. This information might also
be used for capping the number of times a specific visitor to a website is shown
a particular advertisement, estimating the number of unique users, debugging, or
security and fraud detection.

4.3. LEGAL REQUIREMENTS AND PROFESSIONAL ADVICE

We may also use your personal information where this is necessary to comply with
a reasonable request by a law enforcement or regulatory authority, body, or
agency, or in the defense of legal claims.

We may also use your personal information when obtaining legal and other
professional advice including for audits. We consider this to be in our
legitimate interest in the management of our business.

4.4. WHAT IF YOU DO NOT PROVIDE INFORMATION?

In some cases, we are legally required to collect certain information from you
so we can provide the services you have requested, such as Secure Flight
Passenger Data or Advance Passenger Information when you make a reservation to
fly within, into, or out of the United States, or for point-to-point
international travel. Failure to provide this information will mean we cannot
provide the service.

In some circumstances we need your information to perform our contract with you
or to provide products and services, such as payment details and, on occasion,
credit checking information. If you do not provide this information, we may not
be able to enter into or perform the contract or provide the products and
services.

4.5. AUTHORIZATION ON BEHALF OF ANOTHER CUSTOMER

When you provide information to us about your travel companions or other
individuals (if, for example, you have arranged to make a booking on their
behalf), you confirm to us that you have obtained their authorization to provide
us their information and their consent to your use of their information in
accordance with this Privacy Policy. If you cannot make these confirmations, you
must not provide us with any personal information about these individuals.

4.6. SENSITIVE INFORMATION

We may process sensitive or special categories of personal information, such as
that relating to health, disabilities, race, ethnicity, political opinions,
biometrics, or religion, for the purpose(s) for which it was provided or for
which you have provided express consent. For example, we may collect and receive
sensitive personal information from you when you:

 * provide such information to us, a travel agent, or another third party
   involved in your travel arrangements at the time of or following your
   booking;

 * disclose to us that you have a specific medical condition, will have an
   accompanying service animal, or request specific medical care or assistance,
   such as the provision of an accompanying nurse or wheelchair assistance, from
   us, an airport, or a third party involved in your travel arrangements;

 * make a request that implies or suggests something about you which could be
   interpreted as sensitive personal information, such as a request for a
   specific type of meal that may suggest that you have a certain medical
   condition or hold a particular religious belief;
   
   
 * consent to the collection of your digital image to enable our supplier's
   facial recognition system for lounge access purposes; or

 * provide information required by public health authorities or other government
   agencies as contemplated by 4.1.j.

We occasionally receive personal information from law enforcement agencies and
other sources relating to criminal activity (or alleged criminal activity) and
may use that information where necessary, and where permitted by applicable law,
to detect or prevent unlawful activity occurring during air travel. We consider
this to be in the substantial public interest.

Some services may require the disclosure of sensitive information to third
parties as described in Section 7 of this Privacy Policy. We will notify you of
any right to deny consent in advance of processing sensitive information, where
required by law.

5. Data Retention

We store your information for as long as legally required or for so long as
necessary to support business purposes described in section 4 and consistent
with our record retention policies. In general, this storage will be (i) at
least for the duration of our relationship, (ii) for as long as you can bring a
claim against us and for us to be able to defend ourselves, and (iii) for any
period required by tax, aviation, and other applicable laws and regulations.

Our App will store user-provided data for as long as you use the related feature
of the App, unless you choose to delete the App. Only information provided for
travel clearance, purchases, and related activities will be stored in our
operational systems as needed to provide your requested services.

6. How Delta Uses Cookies, Tags, and Similar Technologies

6.1. COOKIES

Delta uses cookies, tags, and other similar technologies. For simplicity, we
refer to all these technologies as "cookies". These technologies allow us to
recognize your preference information, keep track of your purchases, remember
your SkyMiles number, and facilitate effective Website administration. We use
the information we collect to enhance your visit to the Website and to provide
you with information tailored to your needs.

Your Internet browser(s) will offer you the option to refuse cookies, but doing
so may affect your use of some portions of Delta’s and our SkyMiles Partners'
and promotional partners’ web services. Please refer to your browser options to
learn more about cookie management.

Delta has engaged third party tracking and advertising providers to act on
Delta's behalf to track and analyze your usage of our Website through the use of
cookies, pixel tags / web beacons, and similar technologies. At our request,
these third parties collect, and share with us, usage information about visits
to our Website, measure and research the effectiveness of our advertisements,
track page usage and paths followed during visits through our Website, help us
target our Internet banner advertisements on our Website and on other sites, and
track use of our Internet banner advertisements and other links from our
marketing partners' sites to our Website. To learn about the available
mechanisms for opting out of cookies and technologies related to interest-based
advertising, see the descriptions and links in the table below.

Our Website and App are not configured to read or respond to “do not track”
settings or signals in your browser headings or mobile device settings, which
vary by provider. In lieu of a browser- or device-based opt-out solution, we
have identified in the table below certain Digital Advertising Alliance and
other approved methods for placement of “opt-out” cookies. Our Website and those
of our third party advertisers or other vendors are configured to read and honor
these opt-out cookies, so long as they are present on your computer or device.
If you delete all cookies, you will need to reset your opt-out cookies. Please
be aware that Delta does not control these opt-out processes.

6.2. TYPES OF COOKIES AND TAGS ON OUR WEBSITE

We use these kinds of cookies and tags on our Website and App:

Cookie name / type

Required Cookies:



 

 

 

 

 

 

 

 

 

Performance

 

 

 

 

 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Functionality

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Essential

 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

What these cookies do

Required Cookies are essential for basic and enhanced website functionality and
performance.  Without these cookies, services you have asked for and choices you
have made for better functionality and features cannot be provided.

These cookies, such as those used for Google Analytics, collect information on
how users use our Website, in order to help us fix technical issues or errors,
and highlight areas such as navigation where we can improve our Website. For
example, Google Analytics uses cookie identifiers to track the number of
visitors to the Website, providing us with the volumes and sources of web page
traffic.  This allows us to analyse web traffic patterns and run tests to
optimize web pages and visits against key metrics.


These cookies, such as language preference, help us customize our Website
content based on a user's preferences. They remember the user's choices, their
language, the country pages visited, and any changes the user makes to text size
or other parts of our Website pages. The information these cookies collect may
be anonymized and they cannot track browsing activity on other websites.


These cookies, such as jsessionid, xssid, xssidsec, and dlsite, are essential
for parts of our Website or App to operate. They enable users to move around our
Website and allow us to recognize a user within our Website or using our App, so
that we can provide users with service they asked for, such as remembering the
user's sign-in details.  They are required to maintain a record of your Do Not
Track preferences, so that we may respect them for future visits.




Advertising Cookies:

 

 

 

 

 

Targeting

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Advertising cookies enable us to understand your interests so that we can show
you relevant offers and direct personalized advertising to you


We may use other cookies, such as those used by advertising platforms we may
use, such as Facebook or Twitter, to target and re-target visitors to our
Website and App with digital advertising that is most relevant to the user. 
These cookies are also used to limit the number of times you see an
advertisement or particular content, as well as help measure the effectiveness
of an advertising or marketing campaign. Using existing cookies from many sites
already on your computer, we partner with third party companies to deliver
advertising to specific computers.

The information collected by Google Analytics itself is anonymous, but if you
respond to a marketing email, then a random ID is generated for Google Analytics
which we can use along with your email address to manually identify you from
other information we already hold in your customer profile. We may then use this
information to generate potential sales leads or advertising.

You can find more information about how Google Analytics safeguards your data
at:

http://www.google.com/intl/en/analytics/privacyoverview.html

For more information about digital advertising visit AdChoices
at: www.youradchoices.com.

6.3. WEBSITE TRACKING PREFERENCES AND OPT OUT

To opt out of first party tracking (that is, tracking with cookies placed by
Delta) on our Website, you may choose from these options:

 * Click here to opt out of Adobe analytics and usage tracking on our Website
   
   
 * Click here to opt out of content targeting on our Website
   
   

To opt out of third party tracking (that is, tracking with cookies placed by
persons other than Delta):

 * Click here to opt out of tracking by Network Advertising Initiative members
   
   
 * Click here to opt out of tracking by Digital Advertising Alliance members if
   you are a US resident and here if you are an EU/UK resident
   
   
 * Click here to opt out of the Google Ad Network (DoubleClick,  AdSense)
   
   
 * Click here to opt out of Google Analytics
   
   
 * Click here to opt out of Adobe Site Services

7. With Whom Does Delta Share Your Information?

7.1. IN GENERAL

We may disclose your information we collect or receive:

 * To third parties to process your information on our behalf, or to assist us
   in providing our services and/or products, such as our customer care center
   operators and providers of technical services such as data centers, biometric
   verification services, and online tools.
   
   
 * To the party providing the service or product when you request or purchase
   services or products through Delta that are to be provided by another party
   (for example, a travel segment on another carrier, hotel accommodations, or
   rental car).
   
   
 * To you or those acting on your behalf. Where local regulations require, we
   may obtain your consent in writing for the purpose of allowing someone else
   to act on your behalf.
   
   
 * To our SkyMiles Partners, promotional partners and other Delta Group
   Companies for the purposes described in and in accordance with this Privacy
   Policy. Further information regarding Delta Group Companies is available in
   Delta’s filings with the U.S. Securities and Exchange Commission, including
   SEC Form 10-K.
   
   
 * To other airlines, including members of our SkyTeam alliance, for the purpose
   of servicing your travel, servicing your flight reservation, recognizing
   your loyalty program status, rebooking your flight in the event of an
   unexpected disruption in your travel, or protecting crewmembers, customers,
   and the overall safety and security of our flight operations and those of our
   alliance partners.
   
   
 * where your SkyMiles Program account is associated with your employer’s or
   corporate business account, or when you use your employer’s corporate
   account, SkyBonus/SkyMiles for Business number or a corporate form of payment
   to book your travel, to that employer or company, to third party expenses
   administration providers, to suppliers of corporate travel assistance
   services, to travel agencies and corporate travel managers through which your
   travel was arranged, and to duty of care providers.
   
   
 * To banks, financial firms and payment services for the purposes of processing
   payments and refunds.
   
   
 * To government agencies and authorities, law enforcement officials, law
   courts, or to third parties: (a) if we believe disclosure is required by
   applicable law, regulation or legal process (such as pursuant to a subpoena
   or judicial order); or (b) to protect and defend our rights, or the rights or
   the rights, health, or safety of third parties, including to establish, make,
   or defend against legal claims; or (c) in the interest of public health and
   safety.
   
   
 * To customs and immigrations authorities, which require by law access to
   booking and travel itinerary information including "Advance Passenger
   Information" (passport and associated personal information) for all customers
   prior to travel.
   
   
 * To customers traveling under the same booking as you.
   
   
 * To persons providing services to Delta, including its professional advisers
   (e.g. auditors, lawyers, and technical consultants).
   
   
 * To persons with whom we are discussing selling any part of our business or to
   whom we sell any part of our business.

We may share with third parties anonymous, aggregated information about all our
users.

If your ticket is purchased pursuant to a corporate incentive agreement, we may
disclose information concerning your travel to your employer or corporate travel
manager.

When you use the App, a unique ID (which varies by device manufacturer and
operating system) is read from or associated with your device to be used as an
anonymous identifier for analytics and performance purposes. This ID might be
generated by or shared with third parties providing us with analytics services,
such as Adobe.

If you have questions about third parties with whom Delta may disclose
information, please email Privacy@delta.com

7.2. SOCIAL MEDIA AND MESSAGING PLATFORMS

You may wish to share information regarding your travel or other activities with
Delta on social media and messaging platforms provided by third parties. To
utilize social media and message sharing features, you will be prompted to grant
permissions within those third-party platforms, as you choose. For example, you
will need to allow account login and publishing permissions. If you choose to
contact or interact with us on a third-party social media or messaging platform,
you understand that you are responsible for reviewing and understanding the
terms and conditions, information security practices, and privacy policy
applicable to the third-party platform, and that Delta is not responsible for
how third-party social media and messaging platforms use, share, or protect your
information. The activity on third-party social media and messaging platforms,
and the data processed, stored, and provided on them, including data regarding
interactions with Delta, is governed by the terms and conditions, information
security practices, and privacy policy of those third-party platforms.

7.3. Disclosure of personal information to customers traveling under the same
booking


When you make a booking, you will be provided with a booking reference such as a
confirmation number or record locator number. Your booking reference should be
kept confidential at all times. Disclosing your booking reference to other
customers may allow them to access your booking details through our systems. If
you are traveling with others under the same booking and would not like your
individual booking details to be disclosed to them, you may prefer to have each
person make and pay for separate bookings.

7.4. OPTIONAL BIOMETRICS SERVICES 

Delta offers eligible customers, including eligible customers flying on
Aeromexico, Air France-KLM, or Virgin Atlantic, the ability to improve their
airport experience using optional biometrics services, including facial
comparison technology, at participating airports.

You may choose to use facial comparison technology for identity verification,
including at flight check-in, bag drop, and boarding gates. If you choose to use
facial comparison technology, your image is taken when you would otherwise
present another form of identification. The image is encrypted and sent to U.S.
Customs and Border Protection (CBP) for the purpose of verifying your identity.
If CBP determines that the image matches images associated with your passport or
images in CBP's database, CBP transmits a unique identifier back to Delta
through an encrypted channel. Delta may associate the unique identifier with
other information about you, such as your name and flight number, for the
purpose of providing the relevant service. Delta does not receive any biometric
information.  


For more information about CBP’s facial comparison technology, see the CBP
Traveler Verification Service Privacy Impact Assessment. Please note that if you
choose to use facial comparison technology at TSA check points or during CBP
processing, TSA and CBP control the processing of your personal information, and
this Privacy Policy does not apply.


7.5. Contact Tracing

To promote healthy travel and prevent the spread of COVID-19, all Delta
customers entering the United States, including U.S. passport holders, are
encouraged to provide contact tracing information. Participation in contact
tracing is voluntary unless specified by a specific flight, country, city or
region.  The Centers for Disease Control and Prevention (CDC) in collaboration
with U.S. Customs and Border Protection (CBP) supports domestic COVID-19 control
efforts by making contact information for customers traveling internationally
available to state and local health departments to contact you and provide
follow-up instructions for testing and/or potential quarantine.  Delta shares
this information with the CDC via CBP utilizing established channels for the
Advance Passenger Information System (APIS).   For more information, go to
www.CDC.gov or www.CBP.gov, or see CBP’s Privacy Impact Assessment for the
Advance Passenger Information System for details about how CBP uses APIS
information.

7.6.   Unaccompanied Minors

When children travel alone on our flights, we take every step to make sure the
child is safe.  Delta may disclose information pertaining to an unaccompanied
minor’s itinerary, for example, in ensuring the safety and security of the child
traveling on Delta flights, complying with applicable law and regulations, and
coordinating transportation and other services with the child’s parents or
guardian.

8. Correcting or Updating Your Information or Marketing Preferences; Withdrawing
Consent

If you believe that any information we hold about you is incorrect or
incomplete, or if you want to change your marketing preferences, you have a
number of options:

 * You can log in and visit our SkyMiles Partners and promotional partners on
   our Website if you want to modify your subscription, email or contact
   preferences.
   
   
 * You can withdraw consent you have given us to process your information at any
   time by opting out in your SkyMiles Profile, or by contacting us by using
   the Email Us page.
   
   
 * You may contact us by using the Email Us page if you have questions about
   removing your name from our subscription lists.
   
   
 * You may call our Customer Care Offices at +1-800-455-2720 if you have any
   questions about changing your contact preference or require assistance in
   removing your name from our subscription lists.
   
   
 * Assistance in changing contact preferences for those with disabilities is
   available at +1-404-209-3434.

We will make reasonable efforts to revise any information that is incorrect, or
update or change your information or preferences as we are required to do by
applicable law.

Please see section 6 regarding consents to cookies and tracking.

9. Your Rights

This section 9 applies only to individuals in the European Union, UK and other
countries which grant the rights described here. These rights will apply only in
certain circumstances.

9.1. REQUESTING A COPY OF YOUR INFORMATION

To the extent you are legally entitled, you can request confirmation of whether
or not we process your personal information, and details of the information that
we hold about you and how we use it.

You also have a right to access your personal information and to be provided
with a copy.

9.2. RIGHT TO RECTIFICATION OF PERSONAL DATA

If you believe that the personal data we hold about you is inaccurate, you may
request that we correct it. You may also request us to complete personal data
about you which is incomplete.

9.3. RIGHT TO RESTRICT PROCESSING OF PERSONAL DATA

You have the right to request that we restrict processing of your personal
information where one of the following applies:

 * You claim that the personal data is not accurate. The restriction will apply
   until we have taken steps to ensure the accuracy of the personal data.

 * The processing is unlawful, but you do not want us to erase the personal
   data.

 * We no longer require the personal data for the purposes of processing, but
   you still need it in connection with a legal claim.

 * You have exercised your right to object to the processing. The restriction
   will apply until we have taken steps to verify whether we have compelling
   legitimate grounds to continue processing

9.4. RIGHT TO REQUEST DELETION OF PERSONAL DATA ("RIGHT TO BE FORGOTTEN")

You may request the erasure, suspension of processing or anonymization of your
personal information in certain circumstances. For example, you may request
erasure, suspension of processing or anonymization if:

 * The personal information is no longer necessary in relation to the purposes
   for which it was collected or otherwise processed.
   
   
 * You have withdrawn your consent and we have no other legal basis for
   processing the personal information.
   
   
 *  You have exercised your right to object to processing the personal
   information, and we have no overriding legitimate grounds to continue
   processing it.
   
   
 * The personal information is excessive for the purposes for which it was
   collected or otherwise processed. 

Under certain circumstances, we may refuse a request for erasure, suspension of
processing or anonymization, for example, where we need to use the personal data
to comply with a legal obligation or to establish, make or defend legal claims.

If you exercise your right to erasure or anonymization, this will potentially
remove records which we hold for your benefit, such as your SkyMiles account
information (including miles that may be in your SkyMiles account) and your
presence on a marketing suppression list.

9.5. RIGHT TO OBJECT TO PROCESSING OF PERSONAL DATA

You have a right, at any stage, to object to our using your personal information
to send you marketing information.

You also have the right to object to our using your personal information where
our reason is based on our legitimate interests. We will have to stop processing
until we can establish that we have compelling legitimate grounds which override
your interests, rights, and freedoms, or that we need to continue using it for
the establishment, exercise, or defense of legal claims.

9.6. RIGHT TO DATA PORTABILITY

This right applies where:

 * Our reason for using your personal information is either that you have given
   consent or that the processing is necessary for us to perform a contract with
   you; and

 * We process the personal information by automated means.

This is a right to receive all the personal information which you have provided
to us in a structured, commonly used, and machine-readable format and to
transmit this to another controller directly, where this is technically
feasible.

9.7. COMPLAINTS TO REGULATOR

You have a right to complain to a supervisory authority (i.e., a regulator which
oversees data protection law compliance), for example, in the UK or the European
Union country where you live or work or where you believe we have infringed your
privacy rights.

9.8. Rights Applicable Only in Brazil

9.8.1. Right to request information concerning data transfer

You have the right to request information identifying the public and private
entities with which your personal information has been shared.  

9.8.2. Information on Right to Deny Consent

You have the right to request information concerning the consequences of not
giving your consent. 

9.9. Exercising these rights

We may charge you a small administration fee to respond to your request as
allowed by applicable law. In general, we do not charge any fee where the right
is based on European Union law, UK law, the Brazilian General Data Protection
law, and other applicable laws. (We can charge an administrative fee for extra
copies of your information and in certain exceptional circumstances.) 

Where we receive a request to exercise one of these rights, we will provide
information on the action we take on the request without undue delay and in any
event within one month of receipt of the request. This time may be extended by a
further two months in certain circumstances, for example, where requests are
complex or numerous.


Where we do not carry out your request, we will tell you without delay and in
any event within one month of receipt of the request, and we will explain our
reasons for not taking the action requested.


Any request you make must be in writing and include your name and address and
any other information that may identify you, such as where your request relates
to a travel booking, please provide your booking reference (e.g., confirmation
number or record locator number), SkyMiles Account number if you have one, the
dates on which the travel took place, and any other relevant information that
will assist us to identify your booking. You must also provide a photocopy of
one of the following forms of identification so we can verify your identity:

 * Passport;
 * National ID;
 * Driver’s License; or
 * State-issued REAL ID Compliant Identification document. 

Please send your written requests to:

Data Protection Officer
1030 Delta Blvd
Department 981
Atlanta, GA 30354, USA

Or, you can submit this request to our Data Protection Officer by emailing us at
Privacy@delta.com.

9.10.  Representation

As regards Delta's personal data processing activities regulated by the UK GDPR,
Delta has appointed its branch at Metro Building 1, Butterwick, London as its UK
representative.

As regards Delta's personal data processing activities regulated by the GDPR,
Delta has appointed its branch at Vertrekpassage 1 – 110, 1118 AP Schiphol, The
Netherlands as its European Union representative.

As regards Delta’s personal data processing activities regulated by the China
Personal Information Protection Act, Delta has appointed the following branches
as its representatives:

Room 2105 and 2106, Yueyang Plaza, 1601 Nanjing West Road, Jing'an District,
Shanghai

Room 1008, Beijing Kerry Centre South Tower,No.1 Guanghua Road, Chaoyang
District, Beijing, PR China

10. Minors

Other than information required to complete a booking, Delta does not knowingly
collect personal identifiable information from children under the age of 13. If
a child under 13 has provided us with personal information without parental or
guardian consent, the parent or guardian may contact us by emailing us
at Privacy@delta.com. We will remove the information and unsubscribe the child
from any of our electronic marketing lists. Where required by applicable law, we
may ask children for consent from their parents or guardians before we book
their flight or provide a product or service to them.

11. Links

Our Website contains links to other sites. We are not responsible for the
content or privacy practices of those sites, and Delta’s Privacy Policy does not
apply to information collected from you by those sites. We encourage you to read
the privacy statements of each site that collects information from you. When you
are leaving our Website via a link to interact with a site that is not governed
by this Privacy Policy, a new browser window will open.

12. Information Security

Information Security is important to Delta. We have established appropriate
physical, electronic, and managerial safeguards to protect the information we
collect in accordance with this Privacy Policy. These safeguards are regularly
reviewed to protect against unauthorized access, disclosure, and improper use of
your information, and to maintain the accuracy and integrity of that data.  In
the event of a data breach, we adhere to data breach notification requirements
and incident reporting obligations to supervising authorities and/or data
subjects, as required by applicable laws. The substance and time frames
applicable to these remedies are set forth in applicable laws.  Please note that
your information may be processed on third-party infrastructure that is not
owned by Delta or its affiliates.

13. Data Transfers

Delta is based in Atlanta, Georgia, USA and we may transfer personal information
in compliance with applicable law to the US and other jurisdictions where Delta
provides services.

Some of the countries where Delta operates or where third parties operate on
behalf of Delta may not have the equivalent level of data protection laws as
those in your location. If we need to transfer personal data from your location
to such countries, we will take steps to make sure your personal data continues
to be protected and safeguarded. In particular, we may require parties to whom
we transfer your data to agree to abide by suitable contractual obligations,
such as, in the case of transfers from the EU or UK,  the Model Clauses approved
by the European Commission and permitted under Article 46 of the European Union
General Data Protection Regulation ("GDPR") or the UK secretary of state or
under other relevant body. If you would like to obtain the details of such
safeguards, you can request them from the Data Protection Officer at
Privacy@delta.com. In some limited circumstances, we may also transfer your
information from your location to other countries where permitted by applicable
law (for example under Article 49, GDPR in the case of transfers from the
European Economic Area). This includes where it is necessary for the performance
of a contract between us and you and where the transfer is necessary in
connection with legal proceedings. To exercise your rights with respect to
personal data transferred to third parties, you may submit your request directly
to Delta in accordance with Section 9.

14. Promotional Partners

We want to give you more opportunities to earn miles in the Delta SkyMiles
Program. One of the ways we do this is by sharing your information with
promotional partners. Typically, these promotional offerings are limited in
quantity and geographic reach and targeted to specific demographic audiences. If
you fall within the audience a promotional partners is trying to reach, and
(where required under applicable law) you have consented to receive information
about their services, you may receive a promotional e-mail or direct mail.
Although we select our partners with care, these partners have their own privacy
policies that apply to the way they use your personal data.

If you do not want us to share your information with one of these partners, you
can always opt out by contacting us by using the Email Us page or by calling the
SkyMiles Service Center at +1-800-323-2323.

15. SkyMiles Program

In addition to the Data Transfers explained in section 13, information you
provide in connection with the SkyMiles Program (as summarized in the table at
section 4.1.c.), may be transferred to Delta entities in other jurisdictions,
including the Cayman Islands.  This may include sensitive information as defined
under the Data Protection Law, 2017 of the Cayman Islands ("DPL"), the GDPR, the
UK GDPR, or other applicable law if you have provided such information to Delta
in connection with your SkyMiles account.  Where your information is shared with
a Delta entity established in the Cayman Islands, you may have various rights
under the DPL.  These rights are similar to the rights described in section 9. 
Where your information is shared with a Delta entity established in the Cayman
Islands, you also may have the right to lodge a complaint with the Cayman
Islands Ombudsman.  Any onward transfer of your information by any Delta
entities in the Cayman Islands shall be in accordance with the requirements of
the DPL and may include measures similar to those described in section 13
above.  If you have any questions regarding this section, or if you would like
to exercise your data protection rights under the DPL, please contact our Data
Protection Officer at Cayman.Privacy@delta.com or contact our Customer Care
center by telephone or mail.

In addition, each of SkyMiles IP Ltd. and SkyMiles IP Finance Ltd., whose
address is at c/o Maples Corporate Services Limited, P.O. Box 309, Ugland House,
Grand Cayman, KY1-1104, Cayman Islands, will be a data controller of personal
information of SkyMiles members.  This Privacy Policy constitutes a notice by
such entities to those SkyMiles members about its use of their personal
information, which only concerns the SkyMiles Program.

16. SkyTeam Alliance

Delta is a member of the SkyTeam Alliance, a global network of airlines that
process personal data to provide passengers with a more seamless travel
experience.  For more information, please read the SkyTeam Alliance Joint
Privacy Notice.

Peru

This section describes our specific practices related to the use, storage, and
disclosure of your personal information in Peru and supplements the generally
applicable sections 1 through 14 in this Privacy Policy. It applies to personal
information we collect from or about you when you interact with us in the course
of our providing commercial air travel services, ancillary services, or other
services provided by us or by others acting on our behalf in Peru, including
when you use our Website or our App. With respect to personal data collected or
processed by Delta’s branch office in Peru, the provisions discussed here take
precedence over any inconsistent or deviating provisions set out in the
generally applicable sections 1 through 14 in this Privacy Policy.

1. Updates

Delta reserves the right to modify this Privacy Policy and will post any changes
in an updated version of this policy.

2. How to Contact Us?

For the exercise of data protection rights and/or if you have any questions or
comments regarding this Privacy Policy, please contact our Data Protection
Officer at Privacy@delta.com or contact our Customer Care center by telephone or
mail.

3. How Delta Uses Your Data

This section describes what personal information we collect about you, the
purposes for which we use it, and why we use it. Your personal data will be
collected and processed in accordance with Law N° 29733 - Law of Protection of
Personal Data, and applicable regulations, approved by D.S. 003-2013-JUS. Your
personal data will be incorporated into the Personal Data Database named
"Pasajeros", "Skymiles Usuarios Web" and "Procedimientos, quejas y reclamos”
identified with RNPDP code No. 17069, 17065 and 17063 (Databases). Any
processing of personal data that we perform is in accordance with the provisions
of the privacy laws in Peru, and this data may only be used for the limited
purposes discussed in this section.

The data controller in Peru is Delta’s Branch office in Peru, DELTA AIR LINES
INC. SUCURSAL DEL PERÚ (en adelante, “Delta”), con Registro Único de
Contribuyente No. 20387428331, located at Av. Elmer Faucett 2851, Edificio Lima
Cargo City, Oficina 406, Callao, Lima, Peru.


Information we collect

a. Information related to the provision of our services, including:

 * your first and last name;
 * your national ID number;
 * your postal address, telephone numbers, and email address; 
 * your Skymiles number;
 * your billing and transaction information such as credit/debit card type and
   number(s), related data including associated bank details and billing
   address, and expiration date(s);
 * your date of birth; 
 * your gender;
 * your nationality;
 * your emergency contact information; and
 * information related to your physical and mental health.
    

Purposes for which we use it

We use this information to:

 * manage the requested service;
 * facilitate the provision of complementary services when you have ordered them
   or consented to them;
 * contact you if necessary and/or use your information for any service(s)
   related to the ticket sale;
 * your protection in case of delays or cancellation of the service;
 * provide you with the benefits of the SkyMiles program and the attention to
   complaints.
    

Why we use it


We use this information  for the reasons, and subject to the limitations,
specified below:

 * it is necessary to enter into and perform our contract with you to provide
   flights or other products or services;
 * we have a legitimate business interest in assisting you with making and
   managing your bookings with us;
 * we have a legitimate business interest in managing and administering our
   business and protecting it from fraud;
 * in the case of information relating to your health, and dietary requirements,
   if you have consented to our using it to meet special assistance requests and
   preferences at the point of collection;
 * in the case of our storage of information related to your credit card (beyond
   what is necessary to process your payment), if you have provided your consent
   at the point of collection;
 * we have a legitimate business interest in improving and promoting our service
   and better understanding how customers use it;
 * we do not use your personal information to send you marketing communications
   unless you have provided your consent at the time of collection, which
   communications may include marketing communications related to our SkyMiles
   Program, promotions, communications related to additional services and
   advertisements; 
 * we do not use your personal data to send you marketing communications when
   you provide us with your personal data through the Comments/Complaints form
   on delta.com; 
 * we have a legitimate business interest in ensuring that our technical systems
   operate properly;
 * we must comply with certain regulatory requirements regarding emergencies and
   otherwise in relation to operating passenger flights. We also have a
   legitimate business interest in complying with legal and regulatory
   requirements applicable in Peru;
 * we and third party airlines have a legitimate business interest in making and
   operating connections between multiple flights and expediting baggage
   clearance across international borders;
 * we and our SkyMiles Partners, promotional partners and other businesses that
   are providing services that you request have a legitimate business interest
   in using the information to provide their services; 
 * we have a legitimate business interest in protecting against risks to
   customers and aircraft;
 * we have a legitimate business interest in streamlining customs clearance
   processes for our customers.

4. What if You Do Not Provide Information?


In some cases, we are legally required to collect certain information from you
so we can provide the services you have requested, such as Secure Flight
Passenger Data or Advance Passenger Information when you make a reservation to
fly within, into, or out of the United States, or for point-to-point
international travel. Failure to provide this information will mean we cannot
provide the service.

In some circumstances we need your information to perform our contract with you
or to provide products and services, such as payment details. If you do not
provide this information, we may not be able to enter into or perform the
contract or provide the products and services.

Any processing of personal data that we perform is in accordance with the
provisions of the current data protection legislation of Peru, and this data may
only be used for limited purposes such as those mentioned in this section.

5. Sensitive Information

We may collect or receive sensitive or special categories of personal
information, such as that relating to health, disabilities, race, ethnicity,
political opinions, biometrics, or religion, where permitted by applicable law.
For example, we may collect and receive sensitive personal information from you
when you:

 * provide such information to us, a travel agent, or another third party
   involved in your travel arrangements at the time of or following your
   booking;
 * disclose to us that you have a specific medical condition, will have an
   accompanying service animal, or request specific medical care or assistance,
   such as the provision of an accompanying nurse or wheelchair assistance, from
   us, an airport, or a third party involved in your travel arrangements; or
 * make a request that implies or suggests something about you which could be
   interpreted as sensitive personal information, such as a request for a
   specific type of meal that may suggest that you have a certain medical
   condition or hold a particular religious belief.

We will collect, store, use, and transfer your sensitive personal information
for the purposes for which it was provided and otherwise in accordance with the
terms of this Privacy Policy if you provide your express consent at the time of
collection

6. Data Retention

We store your information for as long as legally required and for so long as
necessary to support business purposes described in the generally applicable
section 3 of this Privacy Policy and consistent with our record retention
policies.

7. With Whom Does Delta Share Your Information?

We may disclose your personal information we collect or receive:

 * to third parties to process your information on our behalf, or to assist us
   in providing our services and/or products, such as our customer care center
   operators and providers of technical services such as data centers and online
   tools; however, Delta requires that third parties comply with Delta’s Privacy
   Policy when processing your information;
 * to the party providing the service or product when you request or purchase
   services or products through Delta that are to be provided by another party
   (for example, Iron Mountain Peru S.A., CORPAC S.A., catering, VIP lounges,
   such as SUMAQ and HANAQ), hotels, transport companies, accounted outsourcing,
   Lima Airport Partners S.R.L., Talma Servicios Aeroportuarios S.A., and
   security companies);
 * to other Delta Group Companies, including Delta Air Lines, Inc., a Delaware
   corporation with registration number 2387598 domiciled in the United States
   of America, for the purposes described in and in accordance with this Privacy
   Policy. Information regarding the Delta Group Companies is available in the
   generally applicable section 7.1 of this Privacy Policy and Delta’s filings
   with the Securities and Exchange Commissions, including SEC Form 10-K.
 * to government agencies and authorities, law enforcement officials, law
   courts, or to third parties: (a) if we believe disclosure is required by
   applicable law, regulation or legal process (such as pursuant to a subpoena
   or judicial order); or (b) to protect and defend our rights, or the rights or
   safety of third parties, including to establish, make, or defend against
   legal claims.

8. Your Rights

This section applies only to the personal information of individuals in Peru
which grants the rights described here.

 * Right to access your personal information

To the extent you are legally entitled, you can request confirmation of whether
or not we process your personal information, and details of the information that
we hold about you and how we use it.

You also have a right to access your personal information and to be provided
with a copy. 

 * Right to rectification of personal data

If you believe that the personal data we hold about you is inaccurate, you may
request that we correct it. You may also request us to complete personal data
about you which is incomplete. We will make reasonable efforts to revise any
information that is incorrect, or update or change your information as we are
required to do by applicable law.

 * Right to restrict the processing of personal data

You have the right to request that we restrict processing of your personal
information where one of the following applies:

o You claim that the personal data is not accurate. The restriction will apply
until we have taken steps to ensure the accuracy of the personal data.

o The processing is unlawful, but you do not want us to erase the personal data.

o We no longer require the personal data for the purposes of processing, but you
still need it in connection with a legal claim.

o You have exercised your right to object to the processing. The restriction
will apply until we have taken steps to verify whether we have compelling
legitimate grounds to continue processing.

 * Right to request deletion of personal data

You may request the erasure of your personal information in certain
circumstances. For example, you may request erasure if:

o The personal information is no longer necessary in relation to the purposes
for which it was collected or otherwise processed.

o You have withdrawn your consent and we have no other legal basis for
processing the personal information.

o You have exercised your right to object to processing the personal
information, and we have no overriding legitimate grounds to continue processing
it.

Under certain circumstances, we may refuse a request for erasure, for example,
where we need to use the personal data to comply with a legal obligation or to
establish, make or defend legal claims. 

If you exercise your right to erasure, this will potentially remove records
which we hold for your benefit, such as your SkyMiles account information
(including miles that may be in your SkyMiles account) and your presence on a
marketing suppression list.

 * Right to object to processing of personal data for specific purposes

You have a right, at any stage, to object to our using your personal information
to send you marketing information.

You also have the right to object to our using your personal information where
our reason is based on our legitimate interests. We will have to stop processing
until we can establish that we have compelling legitimate grounds which override
your interests, rights, and freedoms, or that we need to continue using it for
the establishment, exercise, or defense of legal claims.

 * Right to withdraw your consent

Where you have provided your consent to us for processing your information, you
can withdraw this at any time by opting out in your SkyMiles Profile, or by
contacting us at https://www.delta.com/contactus/commentComplaint.

You may also contact us by using the Email Us page or by calling our Customer
Care Offices at +1-800-455-2720.  Assistance for those with disabilities is
available at +1-404- 209-3434.

9. Exercising These Rights

In order to exercise the rights described in this section, you must submit a
request in accordance with the provisions of the Regulation of Law No. 29733.
Any request you make must be in writing and include your name and address and
any other information that may identify you, such as where your request relates
to a travel booking, please provide your booking reference (e.g., confirmation
number or record locator number), SkyMiles Account number if you have one, the
dates on which the travel took place, and any other relevant information that
will assist us to identify your booking. You must also provide a photocopy of
your passport or driver’s license so we can verify your identity. Please send
your written requests to our Data Protection Officer by emailing us at
Privacy@delta.com.

10. Security

Information Security is important to Delta. We have established appropriate
physical, electronic, and managerial safeguards to protect the information we
collect in accordance with this Privacy Policy and to protect against
unauthorized access, disclosure, loss, misuse, alteration, and improper use of
your information, and to maintain the accuracy and integrity of that data. 

11. Complaints to Regulator

You have a right to file a complaint with the National Authority of Personal
Data Protection by addressing the front desk of the Ministry of Justice and
Human Rights (Calle Scipión Llona 350, Miraflores, Lima Peru) in connection with
your rights under this Privacy Policy.


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