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FINNAIR PRIVACY POLICY




HELLO. WE WANT TO MAKE SURE YOU ARE ON BOARD WITH US WHEN IT COMES TO THE USE OF
YOUR DATA.

This Finnair Privacy Policy tells you how we collect, use, disclose and in other
ways process your personal data. Here, we also explain your rights, how to
contact us and how we safeguard your data.

This Privacy Policy applies to all the personal data we process about you when
you plan your trip, travel with us, purchase or use our services, visit our
online services or otherwise interact with us. We process personal data in
accordance with the provisions of the European Union General Data Protection
Regulation (“GDPR”) and other applicable data protection legislation.

You can find more information about the processing of your personal data under
each topic below. Please click the relevant section below for more information.


YOUR PRIVACY IS OUR PRIORITY.


ABOUT US

DATA CONTROLLER

Finnair Plc
Business ID: 0108023-3
Address: Tietotie 9 01530 VANTAA, FINLAND

PRIVACY ONLINE SERVICE

Manage your privacy settings and request your personal data on the Finnair
website at https://privacy.finnair.com.

DATA PROTECTION OFFICER

If you don’t find what you’re looking for in this policy or the Privacy Online
Service linked above, you may contact the Finnair Group Data Protection Officer:
privacy@finnair.com or Finnair Data Protection Officer, PO BOX 15, 01053
FINNAIR, FINLAND.


YOUR DATA, YOUR RIGHTS

HOW TO USE YOUR RIGHTS

You can use your rights at privacy.finnair.com.

You will always receive a confirmation of the action we have taken on your
request (for example, confirmation of deletion). We will let you know if we
cannot fulfil a request you have made, and the reasons behind such decision.
Making a personal data request is free of charge once every six (6) months. For
additional requests during this time frame, we may charge a reasonable fee to
cover the administrative costs involved. We reserve the right to reject requests
that are unreasonably repetitive, excessive or clearly unfounded.

RIGHT TO ACCESS

You have the right to access and be informed about the personal data we process
about you. You can view some data directly in our digital channels, and you may
request a copy of your personal data at privacy.finnair.com. We will provide you
with it unless we have lawful reasons not to share this data or if sharing the
data would adversely affect the rights and freedoms of others.

RIGHT TO CORRECTION

You have the right to rectify or update inaccurate or incomplete personal data
we have about you. You can update some of your personal data through our digital
channels, and you have the right to request a correction of your contact details
or other personal data by contacting us.

RIGHT TO ERASURE

You may ask us to delete your personal data, and we will erase such data without
undue delay, unless we have a lawful reason to continue processing the data,
such as for delivering the requested services or if there is a legal requirement
or lawful right for us to retain personal data.

RIGHT TO RESTRICT AND TO OBJECT

You may ask us to restrict the processing of your personal data, for example
when your request to correct or remove your data is pending, or if you have
objected to the processing of your personal data and the clarification of the
grounds for such processing is pending.

You have the right, at any time, to prohibit us from using your personal data
for direct marketing purposes, which includes profiling related to such direct
marketing. You can unsubscribe from marketing communication via the
“unsubscribe” link or by other means included in each marketing message. If you
are a Finnair Plus member or Finnair account holder, you may also change your
direct marketing preferences in your Finnair Plus or Finnair account profile.

RIGHT TO WITHDRAW YOUR CONSENT

You have the right to change your mind and withdraw any consent you have
previously given to us. If you are a Finnair Plus member or Finnair account
holder, you can withdraw your consent in your Finnair Plus or Finnair account
profile.

RIGHT TO DATA PORTABILITY

You have the right to receive the personal data you have given to us in a
structured and commonly used electronic format, and to independently transmit
those data to a third party.

LODGING A COMPLAINT

If you feel we have not handled your personal data correctly, you can contact
the data protection supervisory authority and lodge a formal complaint.


SAFEGUARDING YOUR DATA

HOW WE PROTECT YOUR DATA

Finnair takes appropriate technical and organisational measures to ensure the
security of your personal data and protect it against loss or unlawful use.
Access to your personal data is restricted on a need-to-know basis and by access
controls, and the processing of personal data is logged. Our information
technology environment is appropriately protected and monitored, with regular
updates, testing and assessment to ensure ongoing security. Our personnel are
trained to comply with applicable data protection legislation as well as the
applicable policies and instructions.

INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred and processed outside of your home country
and outside of the European Economic Area. The laws of these countries may not
afford the same level of protection to your personal data.

In these cases, we have taken steps to ensure that appropriate and suitable
safeguards are in place in order to comply with the requirements for
international transfers of personal data under applicable law, such as using
the European Union Commission Standard Contractual Clauses as a safeguard for
the transfer of personal data outside the European Economic Area.

We may also be obliged to transfer your personal data to foreign authorities,
for example to customs or immigration authorities.

IF SOMETHING SHOULD GO WRONG

We do our best to keep your data safe and secure. If, however, there was a
personal data breach that should endanger your privacy, we will inform you in
accordance with the data protection legislation.

YOUR ACTIONS MATTER AS WELL

To protect your own privacy, please avoid sharing your personal data, such as
login information or travel documents, with others or on social media. Please
pay special attention to your Finnair Plus account security and consider
two-factor authentication as advanced security for your Finnair Plus or Finnair
account. Please avoid sending copies of your identification documents or
sensitive personal data (e.g. doctor's certificates) to us by unsecured email;
instead, use web forms or other secure transfer methods provided by Finnair.


CUSTOMER AND PARTNER DATA


WHAT DATA WE PROCESS

IDENTIFICATION AND CONTACT DATA

We collect and process basic information, such as

 * name
 * date of birth
 * gender
 * traveller type (adult, child, infant)
 * title (Mr, Mrs, Ms)
 * contact information, such as address, billing address, ground transportation
   address, telephone number and email address.

Personal information may be processed, for example, regarding the person
travelling, the person making the booking, the emergency contact person, legal
guardians or dependents.

SERVICE-RELATED DATA

In order to make your journey possible, we process booking and ticket
information as well as baggage handling details. This may include:

 * booking reference number, ticket number, pricing information
 * flight details (departure dates and times, flight number)
 * flight itinerary (journey origin and destination and possible stopovers)
 * booking date, travel type (one-way or return)
 * travel class, seat type and number
 * baggage tag codes, routing and possible security screening details.

At your request, we may also process special service request information. These
types of requests may involve, for example, meal information, transporting pets
in the cabin or in the cargo hold, or required special assistance.

We may also process travel document data for passengers travelling to or from
the Schengen area, such as passport number, date of birth, sex, passport
validity period, issuing country and nationality. Visa information and
destination addresses are also collected when required by the destination
authorities.

Please note that all persons in the same flight reservation will be able to
access the data in the reservation (including the data of the travel
companions), available through the My Booking service. Access to My Booking is
terminated shortly after the last flight of the reservation.

When you pay for your trip or other services, we process your payment
information, such as payment method and credit card information.

We may process information on sales channel and ancillary services, such as
pre-ordered meals, travel class upgrades, retail products and other purchases.
We process data about your travel arrangements, such as group information (when
traveling with others under the same booking reference), check-in methods and
travel companions in case of joint check-in.

At selected airports, we also process the data from airport security checkpoints
and automated control gates at the departure gates.

In case you choose to share additional information, by submitting a query or
claim through our customer services channels, this data will be processed by
Finnair.

If you are a member of Finnair Plus or a member of our alliance partner’s
loyalty program, we collect and process information such as frequent flyer
number, program and tier information, if you have provided your frequent flyer
number.

If you book additional transport or parking services through Finnair, we will
process transportation address information, service reservation number
information, registration plate numbers, ticket information and given additional
information, such as the size of the vehicle or written free format information
relating to your booking.

COMMUNICATION DATA

We may collect and process your communication with us. This can include customer
service phone call recordings, chat history, emails, SMS messages and social
media posts (controllership of social media data may rest jointly with the
social media platform provider). We may also process your information in
connection with satisfaction surveys and feedback forms. We may process your
direct marketing-related consents and opt-outs (unsubscriptions).

DATA COLLECTED IN OUR DIGITAL TOUCHPOINTS

When you log into or navigate our digital touchpoints, we will process your
login details, service usage and certain information about devices and
connections of users, such as IP address.

SPECIAL CATEGORIES OF PERSONAL DATA

We limit the collection of special categories of personal data such as
information about your health to a minimum, and only to data given by you.

In connection with your special service requests, we may need to process this
type of information, for example due to a special medical assistance request. We
will process sensitive personal data also in case you need medical clearance or
evidence for Finnair or authorities of admissibility to fly with us.

SECURITY RECORDS

Finnair stores a record of passengers who have previously endangered flight
safety and security or have committed an unruly or illegal act against Finnair
or Finnair staff.

DATA FOR BACKGROUND PROCESSES

We process reservation, payment and baggage data to measure performance and to
prevent fraudulent behaviour (see more in section How we use your data > Based
on our legitimate interest > Background processes).


HOW WE USE YOUR DATA

BASED ON OUR CONTRACT WITH YOU

Providing our services

To create a booking, change a booking and identify all passengers onboard, we
need the personal information of those travelling.

To provide you with services throughout your entire journey with us, your data
will be processed at the airport at check-in and arrival, service desk, lounge,
gate as well as on board. In case of irregularities, we need to reach out to our
customers and, in case of the disruption of traffic, reroute the passengers and
modify their bookings.

To deliver your baggage to your destination, we process the baggage handling
details (e.g. tag codes, routing and possible security screenings).

In case of special service requests, we need to ensure you are provided with the
correct service. For instance, your diet preference will be processed to ensure
that you get the meal of your choice.

We assist you in queries related to your purchases such as flight reservations
or shopping.

In order to help you with any questions, collect your feedback, handle your
complaints, claims and refunds we use your personal data as necessary. We may
also use your identification data to provide you with better service in
disruption situations. We may send you confirmation and informative
communication about your travel by email, SMS or other means.

We may save your contact information, reservation data, contacts and content of
contacts in a customer account to be able to provide relevant customer service.
This information may also be used to identify the customer when getting in touch
with us. To keep you informed about your travel and itinerary, we will need to
reach out to you using your contact details and process your booking details.

If you have enrolled in our other services, we will process the data provided
during registration or booking in order to provide the requested service.

BASED ON OUR LEGITIMATE INTEREST

Communication and engagement

We may process your personal data to send you service-related informational
communications related to services you have purchased or registered for.

We may engage with you to voluntarily participate in developing our services. If
you have participated in a survey, the results are used for analytics and can
also be combined with other data in our database, such as reservation and flight
data, for customer experience improvement purposes. You may be contacted after
the survey for providing additional information. We may also contact a selected
or limited group of persons to participate in testing our new products and
services.

When processing personal data, we rely on our legitimate interest in maintaining
business relationships and communicating with you about our operations and our
events.

Digital touchpoints

Personal data, such as login details and site usage logs, are processed in
connection with providing you services in our digital touchpoints, to ensure
your identity, to identify you across the different touchpoints and to record
usage. Functional cookies are employed to collect data from sessions to ensure
the functioning of our online services. For more information on how we use
cookies, please see our cookie policy.

Personalisation of services

Aiming to continuously improve the customer experience and to make our offering
more relevant to you, we may offer personalised service and content based on an
individual transaction, for example offering services related to your
destination. We may also perform customer segmentation, for instance for
offering upgrades, ancillary services and retail products relevant to the
customer through our digital touchpoints. We may also obtain other information
from the individual transactions, such as the travel purpose.

By identifying the customer and their travel history, we can identify previous
communications, past irregularities, purchased services and travel information.
Accordingly, we can recognise the specific traveller’s needs and pay special
attention to certain elements of the customer journey, experience and
interactions. To identify the customer and create one unique customer profile,
multiple records need to be linked, both for the same and across different
transactions.

Background processes

As part of running our business, we may process personal data when carrying out
certain background processes. For tickets, ancillaries and other purchases, we
need to make sure bookings are created and ticketing is done in compliance with
law and Finnair policies. These processes cover, for example, monitoring of
fraudulent activities, such as credit card theft, false bookings, fraudulent
claims, and auditing of fares and taxes.

For developing and improving our services further and to analyze our business
performance, we follow traffic flows, commercial and operational performance and
related customer behaviours. Transactional data is used in operational
situations to determine, for example, how many people will be upgraded or
offloaded.

BASED ON YOUR CONSENT

Direct marketing

If you have given us your consent, we will send you direct marketing messages.
For instance, if you have subscribed to our Finnair newsletter or other direct
marketing material, your contact details will be processed to send you the
requested messages. Customers have the right to unsubscribe or opt out of
receiving marketing messages at any point.

We may also send you direct marketing related to Finnair services based on
applicable legislation on privacy in electronic communications, if you are an
existing Finnair customer or a representative of our supplier, partner or
subcontractor and have not unsubscribed (opted out) from receiving direct
marketing.

Digital touchpoints

In addition to enabling our online services, we use cookies for collecting
personal data for the purposes of providing service analytics, personalisation
and advertising based on your consent. For more information on how we use
cookies, please see our cookie policy.

Processes including special categories of personal data

If the processing of your health-related data is necessary, explicit consent
will be requested from you. You may be asked to provide additional information,
such as a doctor’s certificate to ensure you can travel according to the
evaluation of a medical professional, and to ensure that we have the required
information to take care of your safety and security. Once consent has been
received, the data will be processed, for example, by customer care, ground
handling and inflight crew, only to the extent necessary. Based on your consent,
we may also process data obtained e.g. from healthcare providers, if this is
necessary to verify admissibility to our flights and/or into a foreign country,
during a public health crisis.

BASED ON OUR LEGAL OBLIGATIONS

Ensuring a safe and secure travel

To provide you with safe and secure travel, and for complying with the safety
requirements such as reporting incidents, we need to make sure we know who is on
board the aircraft. We identify passengers with check-in, at the gates and in
coordination with security services.

In cases where a passenger has interfered with or may compromise flight safety,
security or order during or in connection with a flight, we have the right to
refuse to accept the passenger on our flights due to security reasons. This
decision may be made for a fixed period or until further notice. This also means
that we will record the related passenger information in our security records.
We will also define the length of the term during which the passenger cannot
board our aircraft. We will inform the passenger about storing their information
in our security records.

Local laws may require us to share your personal data with authorities, for
example border control agencies, customs, immigration authorities, health
authorities, police or tax authorities. In order to comply with the legal
obligations, we collect and process personal data such as passport details, visa
information and your address in your travel destination as required by
legislation or authority requirements.

In the event of crises, Finnair may process your data for the purpose of
providing care and assistance as well as in order to respond to the situation
and meet our legal obligations.

Keeping required records

Based on accounting legislation, we are required to store our transactions and
other accounting material for the time period defined by the law.

STORAGE PERIOD

We keep your personal data only for as long as necessary for us to fulfil the
purpose for which it was collected, or in so far as data storage is necessary
for compliance with legal obligations and for solving potential claims or
disputes.


HOW WE COLLECT AND SHARE YOUR DATA

SOURCES OF DATA

We receive your data directly from you when you purchase our products in one of
our channels, when you make a booking at finnair.com or when you sign up for our
loyalty program.

We automatically collect personal data when you use our digital touchpoints or
certain services, such as check-in, submitting baggage or boarding.

We may get information from the authorities or third parties. We might get your
information from other airlines if we are involved in realising a part of your
travel. We might also get your data from other partners, such as partners who
are involved in realising the travel, for example Finavia, ground handlers,
third-party platforms or travel agents.

SHARING YOUR DATA

We may share your personal data with Finnair group companies and other third
parties for the following purposes:

For your travel and other services

We share your personal data with, for example, other airlines, airport operators
and other service providers involved during your travel. We also transfer
personal data to service providers involved in handling your reservations,
purchases and bookings. We may also transfer your personal data to travel
agencies, ancillary service providers, authorities and ground handlers, in
accordance with the services requested. If you have booked your flight through a
travel agent or third-party platform, we share your personal data with them.

If you have purchased a medical testing package through Finnair, we may disclose
basic data concerning you (name, sex, date of birth, phone number, email
address)(if available) to the testing service provider, solely to facilitate the
registration and testing process.

We share your data with other airlines that are part of your travel, for example
if one of your flights is operated by another carrier, and with alliance member
airlines for the assistance of alliance customers.

For Finnair Group internal purposes

We may share personal data collected with the help of cookies on Finnair’s
digital services to members of the Finnair Group.

For legal obligations, security and fraud prevention or based on your consent

We may share your data, such as passport, visa information and travel-related
data as required by your destination country’s authorities.

We may also share your personal data with relevant third parties or authorities
if it is necessary to detect and prevent crime, fraudulent activities or
security issues or for other legal reasons. In case of an international public
health crisis, we may disclose health-related information to relevant
authorities based on your consent or a legal obligation.


FINNAIR PLUS MEMBER AND FINNAIR ACCOUNT DATA


WHAT DATA WE PROCESS

PROFILE DATA

We collect and process the basic personal data you submit about you or your
children when creating your Finnair Plus or Finnair account profile. This may
include the following information:

 * name
 * date of birth
 * gender
 * family size and other residential information
 * title (Mr, Mrs, Ms)
 * contact information, such as addresses, telephone number and email address
 * occupational data – profession or occupation, name of employer, employer
   address and work telephone number
 * travel document information – passport number, passport validity period,
   issuing country for passport and nationality.


We process information regarding your membership status and history as well as
data regarding your personal preferences and your use of membership benefits.
This includes the following information:

 * membership and profile information – membership commencement date, type and
   campaign, seat preference (aisle or window)
 * membership card information – membership number, date of issue of last
   membership card, expiry date
 * membership tier information – tier history, tier points total, number of tier
   flights, membership tier, flight ticket price accrual, tier date details
 * Avios and tier points information – total Avios and tier points collected
   during membership, total Avios spent, total Avios available, total expired
   Avios
 * transaction data – all transactions and purchases that involve your
   membership
 * event-specific information – date of event, event details, such as product
   name, Avios and tier points collected or spent, service provider’s name,
   document number (ticket number or another document number) 
 * information about whether the customer has a combined Finnair Plus credit
   card
 * interests and preferences – leisure interests, meal preference and other
   interests provided by the member
 * marketing data – dispatch dates of marketing communications and Avios and
   tier point statements, details of campaigns offered to customer and copies of
   marketing letters sent to customer 
 * airport services – information about airport services, such as the use of
   lounge services, check-in services and baggage handling services and other
   airport service details
 * Direct marketing-related consents and opt-outs (unsubscriptions).


Your profile also contains the data of your flights as Finnair Plus member or
Finnair account holder:

 * flight number
 * point of departure and destination of the flight
 * travel class
 * airline code
 * travel agency that made the booking
 * price information of the ticket
 * code name for business travel booking and other booking information
 * travel partner information – name of the partner


HOW WE USE YOUR DATA

BASED ON OUR CONTRACT WITH YOU

Providing our services 

As part of the Finnair Plus program, Finnair records your transactions.
Transactions include Avios and tier points accrual and redemption. This enables
us to calculate your account balance. We may send you information about your
Avios and tier point balance and about program changes. 

We also process the data that is provided by you in your Finnair Plus or Finnair
account profile. In your profile you may choose to share your preferences and
interests. These preferences may be used for pre-filling information when making
a booking on the Finnair website or to provide more relevant service.

When you enrol in special events, we will process the participant list. The same
applies to marketing competitions and prize draws.

Enabling partner services 

The Finnair Plus partners are a notable part of the Finnair Plus program, as you
can collect Avios and tier points and spend Avios when using partner services.
For this reason, Finnair sends information about partner services and benefits
to members together with information regarding the Finnair Plus program and
Finnair services. More information about partners is available on the Finnair
website.

To provide the partner service and to keep your account balance up-to-date,
Finnair also exchanges data with the Finnair Plus partners. If you use Avios
with a partner, Finnair will be informed. Similarly, if you accrue Avios or tier
points with one of our partners, we will be informed so you are awarded the
Avios and tier points correctly. In order to recognise our customers also
through our partners’ services, we may send relevant member information. In case
of queries or complaints related to partner services, we might correspond with
the partners and share relevant member information.

Communication and engagement

The data recorded is also used for targeted member communication distributed in
the Finnair mobile application, the Finnair website and in our other channels.

We may use the data recorded to communicate with you about your account and
program features and benefits. For instance, these messages may include but are
not limited to when your Avios are due to expire or if you are close to the next
tier.

In order to provide you with the correct information about our member offers on
third-party channels, we may send a list of member emails to the respective
third parties. This ensures that the right offers are displayed when you are
identified as a Finnair Plus member.

BASED ON LEGITIMATE INTEREST

Communication and engagement

As part of improving our customer communications, we may follow up on the
frequency and engagement of how often these messages lead to further actions on
your part in order to calculate the metrics such as click rates.

Analytics 

We may use your personal data for analytics, customer recognition and for
providing personalised services and customer recognition. This enables us to
provide our customers relevant services and products as well as develop our
products and concept and create unique customer profiles. Profiles may be used
for targeting marketing and content in our digital channels, for example the
Finnair website, our mobile application or newsletters distributed by email.
Direct marketing involves member-specific variation in the advertising content
in the above-mentioned channels. Direction of individualised advertising at
members is an integral part of the Finnair Plus program. Having a complete view
of our customers enables us to understand your entire experience and helps us to
improve our products and services and your experience. We may also derive other
metrics based on your customer behaviour, for example, the likelihood of
purchasing certain products, create customer segments, predict other products or
destinations you may be interested in.

BASED ON YOUR CONSENT

Direct marketing

Direct marketing messages are sent to members who have given their consent to
receive such messages. These marketing materials may include offers from
partners, depending on your direct marketing settings.

We may also send you direct marketing related to Finnair services based on
applicable legislation on privacy in electronic communications, if you are an
existing Finnair Plus customer and haven’t opted out of direct marketing.

BASED ON OUR LEGAL OBLIGATIONS

Keeping required records

Based on accounting legislation, we are required to store our transactions and
other accounting material for the time period defined by law.

STORAGE PERIOD

We keep your personal data only for as long as necessary for us to fulfil the
purpose for which it was collected, or in so far as data storage is necessary
for compliance with legal obligations and for solving potential claims or
disputes.


HOW WE COLLECT AND SHARE YOUR DATA

SOURCES OF DATA

We get your data when you join as a member and submit your data for the purpose
of creating and maintaining your account. We get your data directly from you
when you purchase our products on one of our channels or enrol in one of our
services (for example when making a booking on finnair.com). Your purchases will
be linked to your account if you have identified yourself as a Finnair Plus
member.

We also get your data from partners when utilising their services using your
Finnair Plus account. This is necessary for providing the services of the
program.

We automatically collect personal data when you use our services where you are
identified by your Finnair Plus number, such as check-in services and submitting
baggage, by using loyalty services or when purchasing ancillary products.

SHARING YOUR DATA

We may share your personal data with Finnair Group companies and other third
parties for the following purposes:

For providing services related to your membership and developing these services

We share your personal data with, for example, other airlines, airport
operators, program partners and other service providers directly involved in
providing services related to your membership or the development activities of
these services.

For legal obligations, security and fraud prevention

We may share your personal data with relevant third parties, if necessary, to
detect and prevent crime, fraudulent activities or security issues, or for other
legal reasons.

Published 09.03.2024

Navigated to page: Finnair privacy policy


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