Airbus S.A.S. and its Affiliates1 (also known as, “Airbus”, or “we” or “us”) is committed to protecting the rights of individuals in line with the General Data Protection Regulation (reference EU 2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred to as : ‘GDPR’) as well as each applicable national Personal Data protection laws and regulations (collectively referred as “Data Protection Laws and Regulations”).
The protection of your privacy and Personal Data is an important concern to which we pay special attention throughout our business processes and we want you to feel comfortable working with Airbus and/or using our websites, portals and “apps” (“Website(s)”). Personal Data collected in the course of your business relationship with Airbus and/or during use of our Websites is processed by us according to the legal regulations valid for the countries in which Airbus is leading its business activities and/or the Websites is maintained. However, your business relationship with Airbus and/or the Website might include links to other websites or applications which are not necessarily covered by this Privacy Notice. In this event, we encourage you to carefully read the relevant privacy policies.
Unless a specific privacy information notice is set up for a processing as defined here below, this Privacy Notice will inform you of the Personal Data we collect in the course of Airbus business activities; how we use and disclose your Personal Data; how you can control the use and disclosure of your Personal Data.
What is Personal Data?
Personal Data is information that can be used to identify a person either directly or indirectly (hereinafter referred to as ‘Personal Data’). A ‘personal identifier’ is a piece of information that can identify an individual. This definition covers a wide range of personal identifiers which constitutes Personal Data, including name, address, email address, identification number, location data or online identifier.
Special category of Personal Data is any Personal Data which relates to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, sex life or sexual orientation and includes genetic data, and biometric data where processed to uniquely identify an individual (hereinafter referred as : ‘Special Category Personal Data’).
Which sources and what Personal Data do we use?
In the course of the contractual or client relationship between you or your organisation and Airbus and/or access and use of Airbus Website(s), we will collect, use and process Personal Data you provide when relevant, such as the following categories of data:
- Identification data: Name, First name, Date of Birth, contact details (job title and function, professional phone number, employer name), images, videos, voice.
- Economic and Financial data: for processing payment/s and fraud prevention such as IBAN of your organisation, Bank ID Number, other billing information,(…)
- IT data: IP address, user account, login, logs activities, date and length of your visit on our Websites, the pages you view, (…)
We may collect this Personal Data cumulatively:
- directly from you by completing a form, by entering contact details, by navigating to our Website(s),
- indirectly from your organisation you are working for when needed for one or several purposes as listed below.
What are the purposes of the processing of your Personal Data?
By working with Airbus and/or using the Website(s), Airbus may process your Personal Data for the following purposes (hereinafter referred as the “Purposes”) such as :
1. Website Browsers / Administration.
- We may use your Personal Data for administrative purposes, including to help us better understand how our customers, suppliers, third party access and use our Websites; to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us; and to enforce our policies, directives and processes.
- Under the conditions permitted by law and when relevant, we may use your Personal Data for marketing and promotional purposes, including communications through email or equivalent electronic means. For example, we may use your Personal Data, such as your email address, to send news and newsletters, special offers, promotions and competitions, or to otherwise contact you about services or information we think will interest you.
- We may use your Personal Data to communicate with you, including responding to requests for assistance. We can communicate with you in a variety of ways, including email and via your social media accounts if you have agreed, and/or text message.
- We may use your Personal Data for our Internal and external communication media (such as Airbus TV, AirBuzz magazine, campaigns…), Airbus social network (HUB) or public social media but also for event management (conferences, fairs, seminars and airshows)
- We may collect your personal information in order to inform on Airbus, its financial results, its products and other interested Airbus related matters. Information includes regular updates on major events like publication of financial results, our newsletter to shareholders, investors and financial markets, invitations for events, surveys, dedicated campaigns and other elements related to Airbus business, securities and performance.
4. Performance of Airbus business activities and Customer services.
- We may use your Personal Data for Airbus sales and customer services activities, including customer relationship management, for technical support or other similar purposes and to establish and maintain customer accounts).
- We may process your Personal Data in the course of Airbus Procurement activities (new products or services contracts and supplier management,(…).
- We may process your Personal Data in the course of Airbus public affairs management and/or Intellectual Property rights management, guest travel management, (…).
5. Research and development.
- We may use your Personal Data for research and development purposes, including improving our websites, applications, services, and customer experience and for other research and analytical purposes dedicated to improving our products, services, businesses, operations and processes.
6. Security and Health & Safety
- We may use your Personal Data for user access right management and monitoring in Airbus Websites, IT security management, access badge management, site admission, visitor booking security video surveillance (CCTV), first response units, security clearance and/or health & safety procedures.
7. Legal compliance.
- We may use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery request (whistleblowing, internal investigations, know your customers, conflict of interest management, litigation management, comply with Health & Safety regulations,...).
8. To protect us and others.
- Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.
We will use your Personal Data for the above Purposes only, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence under the applicable Data Protection Laws and Regulations, or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you with the relevant privacy information notice.
What is the legal basis for processing of your Personal Data?
We process your Personal Data in accordance with the provisions set out in the applicable Data Protection Laws and Regulations. The legal basis for processing your Personal Data are:
1. To comply with contractual obligations.
When you subscribe to a particular service through the Website, the purposes of processing your Personal Data are primarily determined by that service and we will process your information so that we can provide that service to you.
2. As a result of your consent.
When you have consented to the processing of your Personal Data by us for certain services through the Website, you can withdraw consent at any time by following the instructions provided in the application process or by contacting us at email@example.com. For further information on the right of withdrawal, please see below Section “How to exercise your rights and/or contact Airbus in respect of your Personal Data?”
3. Within the scope of a legitimate interest.
On occasion taking into account the minimum privacy impact for you, the processing of your Personal Data might be necessary for the following legitimate interest:
- For the administration and management and performance of our business relationship including accounting, auditing, performance of the contract.
- For the analysis and optimisation of the Website.
- For ensuring IT security (to detect security threats, frauds or other malicious or criminal activities) and the IT operation of Airbus.
- For prevention and investigation of criminal acts.
- For ensuring efficient communication and to keep you up-to-date on the latest information about our services, solution and/or business activities, events, marketing campaigns, market analysis or other promotional activities and for analysis and improving the quality of our services and communication with you.
- For monitoring the compliance with our policies and standards.
- For security purposes, in particular managing access to our premises.
4. On the basis of Airbus’ legal obligations or in the public interest.
Airbus, as any other company, is subject to legal obligations and regulations. In some cases the processing of your Personal Data will be necessary for Airbus in order to fulfil these obligations.
Who will receive your Personal Data?
We may disclose your Personal Data to the following recipient(s) on a strict need to know basis and for the Purposes as outlined in this Privacy Notice:
- Airbus and its affiliates;
- Authorised persons working for or on behalf of Airbus, including our agents, service providers and advisers providing the variety of products and services we need such as IT services, maintenance and support, procurement services, compliance and security services, etc.);
- Airbus business partners in connection with Airbus activities (flight school, training centers, etc…)
- Other authorised third parties in connection with a reorganisation, merger or sale of Airbus businesses, and/or assets;
- Law enforcement or any relevant authorities where necessary to comply with applicable law.
Which countries and/or regions may Airbus transfer your Personal Data to?
Airbus processes your Personal Data mostly in the EEA and UK. On occasion Personal Data might be transferred outside of the EEA to recipient(s) (including Affiliates) as defined in the section “Who will receive your Personal Data?” that are subject to appropriate safeguards through the legal framework of our Binding Corporate Rules (“BCR”) for transfer to Airbus Affiliates that can be found on our website www.airbus.com or viewed here Airbus BCR's or – through standard contractual clauses or an adequacy decision.
Our Binding Corporate Rules allow us to transfer Personal Data within our international organisation for Airbus daily business activity and internal organisation, and they include a list of countries (see below) which are structured to allow us to transfer Personal Data to Airbus affiliates located in those countries onr a need to know basis. For Airbus, EEA (e.g. France and Germany) is where most of our processing of Personal Data takes place. Below is a list of countries/territories where Airbus Affiliates are located, having signed the BCR and which might have access to your Personal Data where it is relevant.
Australia, Belgium, Brazil, Canada, Chile, China, Denmark, Finland, France, Germany, Hong Kong, Hungary, India, Indonesia, Ireland, Italy, Japan, Kazakhstan, Malaysia, Mexico, Morocco, Netherlands, New Zealand, Oman, Philippines, Poland, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovakia, South Africa, South Korea, Spain, Switzerland, Taïwan, Thailand, Tunisia, Turkey, United Kingdom, United Arab Emirates, Uruguay, United States of America.
How long will your Personal Data be stored?
We process and store your Personal Data as long as it is required to meet our contractual and statutory obligations. The retention period of your Personal Data is determined by applicable Laws and Regulations and/or by our procedures or processes adopted in accordance with applicable Laws and Regulations.
What about the security of your Personal Data?
We use technical and organisational security measures in order to protect the Personal Data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons.
Our security procedures are continually enhanced as new technology becomes available by relevant Airbus departments
What are your rights?
Under some circumstances provided by law, you may at any time exercise your Personal Data protection rights as listed below by contacting us at the contact details mentioned in section “How to exercise your rights and/or contact Airbus in respect of your Personal Data?”:
- Right to access/obtain a report detailing the information held about you: You have the right to obtain confirmation as to whether or not your Personal Data is being processed by Airbus and if so, what specific Personal Data is being processed.
- Right to correct Personal Data: You have the right to change any inaccurate Personal Data concerning you.
- Right to be forgotten: In some cases, for instance, when the Personal Data is no longer necessary in relation to the Purposes for which they were collected, you have the right for your Personal Data to be erased.
- Right to restrict the processing of your Personal Data: You have the right to restrict the processing of your Personal Data by Airbus, for instance when the processing is unlawful and you oppose the erasure of your Personal Data. In such cases, your Personal Data will only be processed with your consent or for the exercise or defense of legal claims.
- Right to data portability: Under some circumstances provided by law, you have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another data controller.
- Right to object: In some cases defined in law, you may ask us to stop processing your Personal Data.
- Right to withdraw consent: Where your consent is required, you may at any time withdraw such consent. However, please note that if you withdraw your consent, you may not be able to access and use certain information, features or services.
How to exercise your rights and/or contact Airbus in respect of your Personal Data?
If you want to exercise your rights or if you are unhappy with the way in which your Personal Data has been processed or should you have questions regarding the processing of your Personal Data, you may refer in the first instance to the Airbus Data Protection Officer, who is available, at the following email address: firstname.lastname@example.org or you can write to the address below: Airbus SAS, Head of Data Protection, 2 rond-point Emile Dewoitine 31700 Blagnac cedex. France.
In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document.
Is your Personal Data the basis for automated decision-making, including profiling?
As a matter of principle, we do not use fully automated decision-making processes including profiling. In the event that we should use such processes in individual cases, we will, specifically inform you in advance of this and of your rights in this respect as required by law.
How to ask for assistance to the competent authorities?
If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority. Listed below are the four main countries where Airbus operates and the relevant Supervisory Authority.
FRANCE: CNIL: Supervisory Authority France
GERMANY: each federal state has its own Data Protection Authority that can be found under the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
SPAIN: AEPD: Supervisory Authority Spain
UK: ICO: Supervisory Authority UK
Additional Notice for California Residents
In addition to the information provided above, the following section is made specifically pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).
We don’t sell your personal information to third parties and we will not sell your personal information to third parties unless provided otherwise by a specific privacy notice. We do not discriminate against California residents who exercise their CCPA privacy rights.To exercise your California privacy rights please refer to the section “How to exercise your rights”.
WHAT ARE COOKIES?
Cookies are small files or amounts of information that may be stored to, accessed and removed from your device when you access Airbus Websites.
They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
(i) to record the preferences of our users,
(ii) to enable us to optimise the design of our Websites,
(iii) to ease navigation, and increase the user-friendliness of our Websites,
(iv) to analyse the usage our Website and/or to identify the most popular sections of[our Websites,
(v) to provide content that is more accurately suited to your needs, and, in doing so, improve our Websites. cookies can be used to determine whether there has been any contact between us and your device in the past,
(vi) to facilitate secure online access so that you do not need to enter your user ID and password again when you access our Websites.
WHICH COOKIES DO WE USE?
Cookies contain Personal Data. The table below aims to inform you about the type and purpose of each cookies, the issuer (Airbus or third party) and the type of Personal Data processed inside, and that we may use on our Websites: