3.1. To Provide our Services
A) Based on our contract with you (Art. 6(1)(b) GDPR)
We process your personal data, including identification and contact data, service-related and special service data, travel document, payment and communication data in the necessary scope to fulfil our contract with you and to provide and execute further services requested by you. These include in particular:
Booking – To create or change a booking and to identify all passengers onboard, we need the personal information about those travelling.
Throughout your journey – To provide you with our services throughout your entire journey, your data will be processed at the airport at check-in and arrival, at service desks, lounges, gates as well as on board the aircraft. In case of irregularities, we need to reach out to you to modify your booking and to reroute and provide other assistance to you.
Baggage – To deliver your baggage to your destination, we process the baggage handling details, such as baggage tag codes and information on routing and security screenings.
Special service requests – To deliver your special service request, we process the needed information. For instance, information on your diet preference will be processed to ensure that you get the meal of your choice.
Feedback and claims – We use your data to help you with any questions, to collect your feedback, and to handle your complaints, claims and refunds.
Customer communication – To keep you informed about your travel arrangements, including possible changes, we use your contact details and process your booking details.
B) Based on our legitimate interest (Art. 6(1)(f) GDPR)
We process your data based on our legitimate interest for the following specific purposes:
Surveys and customer experience improvement – We may engage with you to voluntarily participate in developing our services. The results of such surveys are used for analytics and can also be combined with other data in our database, such as reservation and flight data, for improving customer experience. You may be contacted after the survey for providing additional information. We may also contact you to offer you the opportunity to test our new products and services.
Background processes – We process your personal data when carrying out certain background processes for preventing and detecting fraudulent or false booking and ticketing practices, payment frauds, fraudulent claims, unauthorised or fraudulent use of the Finnair Plus accounts, as well as for auditing the correctness of the fares, charges and taxes payable for the goods and services you buy from us.
Service Ban – If we issue you a ban on our services due to your violation of safety or security requirements or of our terms and conditions of service or due to fraudulent activities, we process your identification and contact data as well as such other data that is directly relevant for assessing, issuing and maintaining the service ban. When the grounds for issuing a service ban require mandatory safety and security reporting and mitigation activities, we process your personal data based on our legal obligation.
For developing and improving our services – to analyse our business performance, we follow traffic, 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.
C) Based on your consent (Art. 6(1)(a) GDPR)
We process your data based on your consent for the following specific purposes:
Health-related data – If the processing of your health-related data is necessary to provide you with the assistance or other accommodations requested by you and to take care of your health and safety while travelling with us, you may be asked to provide us health-related information , such as a doctor’s certificate. Your health-related data is processed for ground and inflight service and for customer care and customer complaints handling. Based on your consent, we may also process data obtained from healthcare providers and other third parties, if this is necessary to verify admissibility to our flights and/or into a foreign country, during a public health crisis. In rare situations we may receive and process health-related data from authorities without your consent, for instance in the case of an emergency, pandemic or other severe disruption requiring the processing of your health-related data.
Online travel document verification – We provide you a secure online advance travel document verification service as an option for entering your travel document information manually and verifying the information with our check-in personnel at the airport. This service requires that an image of your travel document and the readable data entries in the image are processed by us. Your data will be shared with the relevant authorities based on our legal obligation to do so.
D) Based on our legal obligations (Art. 6(1)(c) GDPR)
We process your data based on our legal obligations for the following purposes:
Safety and security – We process your data to ensure safety and security of our flights and of our customers, personnel, airports and other facilities used by us.
Authority requirements – To comply with our legal obligations, we process your identification and contact data, passport data, visa information, payment information, travel data, your address in your travel destination, and such other data as is required by law from time to time. Where required by law, we share such data with authorities, such as border control agencies, customs, immigration authorities, health authorities, police, anti-terrorism and national security agencies, courts and tax authorities.
Emergency and crisis situations – To respond to an emergency situation and to provide you and other persons care and assistance, we process your data to the extent required to meet our legal obligations.
Keeping required records – We process your name, title, booking reference number, flight details, pricing information, cardholder's name and hashed card details as required by bookkeeping and anti-terrorism laws.
3.2 Finnair Plus Loyalty Program
If you are a Finnair Plus member, we process your personal data as follows:
A) Based on our contract with you (Art. 6(1)(b) GDPR)
Transactions – We record your Finnair Plus account transactions, such as accrual of tier points and Avios, and the use of Avios, awards, gifts and benefits.
Finnair Plus profile data – To join our loyalty program, you must provide your first name, last name, date of birth, email address, phone number, gender, and country or region. You may choose to share your postal address, payment card and passport data, household size, preferences and interests with us in your Finnair Plus profile. These preferences can be used for pre-filling information when making a booking on the Finnair website or to provide more relevant service.
Communication to members – We will send you customer communication on the status and changes of the services you have bought from us. We will also deliver you email communication related to your Finnair Plus membership, including account creation and deletion, your Avios expiry, milestone rewards, reaching lifetime tiers, and program changes.
The data recorded is also used for targeted member communication distributed in the Finnair mobile application, the Finnair website and in our other channels.
Events, contests and sweepstakes – If you enrol in Finnair Plus events, contests or sweepstakes, we process your name and contact details to add you on the participant list and to record the participation in your Finnair Plus activities.
Finnair Plus partners – 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. More information about partners is available on the Finnair website.
We exchange with our partners data on your accrual and spend of Avios when you buy the goods and services of our partners so that your Finnair Plus account balance is correctly reconciled against your accrual and spend activities. In case of queries or complaints related to partner services, we exchange the relevant information of the service involved to address you query or complaint.
B) Based on legitimate interest (Art. 6(1)(f) GDPR)
Communication and engagement – As part of improving our customer communications, we measure the frequency and engagement of how our communication leads to further actions on your part.
Analytics – We use your personal data for analytics and customer recognition, as well as for providing personalised services to you. 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, and predict other products or destinations you may be interested in.
3.3. Digital Marketing Communications and Content Personalisation
This section of our Privacy Notice describes how we use your personal data for digital marketing and content personalisation.
General Principles
- When we obtain your contact details in the context of a sale of our products and services or if you enrol in the Finnair Plus program, we use these contact details for marketing communications of our own similar products or services and ancillary services related to your trip via email based on applicable legislation on privacy in electronic communications. We will inform you of this and provide you the opportunity to opt out from such use of your contact details at the time we first obtain your contact details and thereafter in each marketing email that you receive from us. You will find the opt-out link at the bottom of the emails, or in your Finnair Plus profile.
- If you are not a Finnair Plus member but have given your consent to receive emails and personalised advertising through our website, the Finnair app or a dedicated sign-up form, you can manage your marketing preferences or withdraw your consent via a link at the end of our emails.
- Withdrawing your consent or opting out from marketing communication later does not affect the legality of the processing of your personal data for marketing communications purposes before you withdrew your consent.
- We conduct targeted advertising based on our legitimate interest. You can opt-out from targeted advertising at any time through your Finnair Plus profile. You may still see our non-personalised, general advertisements on our own digital touchpoints and on third-party channels where we advertise our services.
- We will always send you customer communications on the status and changes of the products and services you have bought from us based on our contract with you.
3.3.1. What Data We Process
Personal identification information – Randomised ID given to you when you visit our digital touchpoints, your name, email address and phone number.
Interaction data – Data about your interactions with our marketing communications (e.g. open rates, click-through rates).
Your transactions with us – Information about the flight(s) and other services you have bought and used with us, and if applicable, history of your collection and use of previous Finnair Plus award points and current Avios and tier points throughout your membership. We will not collect any of your payment details for marketing communications purposes.
Finnair Plus member’s additional personal identification information – Your membership number, date of birth, gender. We will only process your postal address information if you have given that information to us.
Finnair Plus member’s travel profile and interests – Information related to your preferences and interests as a Finnair Plus member if you have given that information to us.
Finnair Plus membership data – Information about the date of becoming a Finnair Plus member, your tier status and personal tracking period in the Finnair Plus program. We will also process data about how much you have spent as a Finnair Plus member and if you have faced some disruptions during your journeys as a Finnair Plus member. We will also process the information about whether you have a credit card related to the Finnair Plus program, and whether you have linked your Finnair Plus account with another loyalty program.
Cookies – We use cookies and similar technologies to improve your experience on our website and mobile application (the “Platforms”), to show you relevant marketing content on the Platforms and across third-party websites and social media networks and to tailor our content and services to match your preferences and interests, as described in our Cookie Policy.
Cookies are small text files that are stored on your device (such as a computer, tablet, or smartphone) when you visit the Platform. When you return to the Platform, cookies help recognise your device and remember certain information about your visit, such as your language preferences, login status, and information entered into forms. This makes the Platform more convenient and personalised. Cookies are grouped into four categories based on their function: essential, performance and content personalisation cookies. Essential cookies are always on whereas performance, content personalisation and advertising cookies are optional.
If performance cookies are enabled, we collect and process the following personal data:
- Personal identification information: Randomised ID given to you when you visit our digital touchpoints. We will not collect any of your payment details for marketing communications purposes.
- Marketing-related preferences: Information about your preferences and interests related to our products and services.
- Behavioural data: Information about your online behaviour, collected through usage of our website and the Finnair app.
If content personalisation cookies are enabled, we collect and process the following personal data:
- Personal identification information: Randomised ID given to you when you visit our digital touchpoints. Additionally, if you complete a transaction or fill any form, we will collect your name, email address and any other details you provide. We will not collect any of your payment details for marketing communications purposes.
- Marketing-related preferences: Information about your preferences and interests related to our products and services.
- Behavioural data: Information about your online behaviour, collected through usage of our website and the Finnair app.
If advertising cookies are enabled, we collect and process the following personal data:
- Personal identification information: Randomised ID given to you when you visit our digital touchpoints. We will not collect any of your payment details for marketing communications purposes.
- Marketing preferences: Information about your preferences and interests related to our products and services.
- Behavioural data: Information about your online behaviour, collected through our website, the Finnair app and third-party channels such as social media interactions.
3.3.2. How We Use Your Data and Legal Bases of Processing
A) Based on our contract with you (Art. 6(1)(b) GDPR)
We will send you customer communications that concern the status, changes, and continuation of the products and services you have bought from us.
B) Based on our legitimate interest (Art. 6(1)(f) GDPR)
Analytics and performance – If you have accepted performance cookies, we measure traffic on our website and the Finnair app, identify returning customers, and understand how our customers use our website and the Finnair app.
To create a profile about you – If content personalisation cookies are enabled and/or you haven’t objected the use of Finnair’s legitimate interest to conduct profiling, we create a profile about you based on your preferences, behaviour and personal identification data for marketing communications and content personalisation purposes. This profile is not shared with any third party unless you have given your consent to receive personalised third-party advertising. The profile will not be used for automated decision-making or profiling that would produce legal effects concerning you.
To enable third-party advertising tracking – If advertising cookies are enabled, we use third-party tracking pixels on our digital touchpoints which are technologies that enable our third-party partners to collect your behavioural data directly from our digital touchpoints. This allows us to optimise, measure and place targeted content on other websites and services through our third-party partners. Please see more information about how we share your data for targeted advertising under the section ‘How we share your data’.
To enrich your profile data – If content personalisation cookies are enabled, the profile that is created based on the data we collected with these cookies is further enriched based on your ongoing engagement with our digital touchpoints and data we have collected from you as our customer and as a Finnair Plus member. This does not include automated decision-making or profiling that would produce legal effects concerning you.
Segmentation and personalisation – We use your profile data to get more insight into how we can better serve you as a customer in the context of our whole customer base. This does not include automated decision-making or profiling that would produce legal effects concerning you.
To personalise our marketing communications content – We tailor the content for our marketing communications channels and personalise content in our own digital touchpoints based on your profile and the other data we collect and process about you (as explained above). This profiling allows us to segment our customer base and provide you with marketing communications content that is relevant to you and is likely to interest you as our potential or existing customer and a Finnair Plus member. This does not include automated decision-making or profiling that would produce legal effects concerning you.
Marketing emails related to your products and services – If we have obtained your contact details in the context of a sale of our products and services or a registration to Finnair Plus program, we can use these contact details for marketing communications of said purchase or program via email based on applicable legislation on privacy in electronic communications, such as promotional emails about Finnair and Finnair Plus products, services, member offers, news and travel inspiration that may interest you, unless you choose not to receive such communication. You can change your marketing communication settings at any time in your profile.
Personalised advertising for Finnair Plus members by sharing and matching your data with our third-party partners – We conduct personalised advertising by sharing your hashed data with third-party partners, such as Meta and Google, to facilitate data matching to enhance and personalise the Finnair advertising you see in these platforms. You can object to this at any time through your Finnair Plus profile.
C) Based on your consent (Art. 6(1)(a) GDPR)
We process your personal data based on your explicit consent for delivering you our marketing communications, in accordance with Article 6(1)(a) of the GDPR. Your consent is voluntary, and you have the right to withdraw it at any time without any impact on the legality of processing based on your consent before its withdrawal.
To deliver you marketing emails related to Finnair and Finnair Plus – If you have given your consent to receive our marketing emails, we will use your personal data to send you marketing emails about Finnair and Finnair Plus products, services, special offers, news and travel inspiration that may interest you.
Personalised advertising regarding Finnair newsletter subscribers that are not members of the Finnair Plus program – We conduct personalised advertising by sharing and matching your data with our third-party partners such as Meta and Google based on your consent, to facilitate data matching to enhance and personalise the Finnair advertising you see in these platforms. You can opt out from this at any time through the unsubscribe link of the newsletter.
To deliver you marketing emails related to Finnair Plus partners and events – If you are a Finnair Plus member and have given your consent to receive our exclusive membership offers from Finnair Plus partners and event invitations, we will use your personal data to send you marketing emails about exclusive membership offers from Finnair Plus partners’ products and services that may interest you, as well as our event invitations. Finnair Plus partners are categorised to Travel, Financial and Retail partners and you can manage your consents to each category separately.
3.3.3. How We Obtain Your Data
We obtain your personal data for digital marketing communications and content personalisation purposes when you:
- Interact with our Platforms.
- Buy a flight or other services and use those services with us.
- Sign up for the Finnair Plus program and buy and use our services as a Finnair Plus member.
- Sign up for our marketing communications.
- Participate in surveys, promotions or events.
- Participate in a campaign or fill in a form on a third-party platform related to our products and services.
3.3.4. How We Share Your Data
We share your personal data with third parties who assist us with:
Production, management and analytics – We use third-party ICT providers to provide us with tools and services to produce and manage our marketing communications and content personalisation activities, as well as help us analyse the performance of our efforts. These ICT providers are contractually obligated to protect your personal data and only use your data according to our instructions on our behalf as our personal data processors. We ensure that these ICT providers comply with the applicable privacy and data protection legislation and that the transfer of your data from us is secure and applies legal and appropriate safeguards when such transfer is needed.
Email marketing – We use third-party providers to facilitate our email marketing campaigns and manage our mailing lists. These third-party providers are contractually obligated to protect your data and only use it according to our instructions as our personal data processors. We ensure that these third-party providers comply with the applicable privacy and data protection legislation and that the transfer of your data from us is secure and applies legal and appropriate safeguards when such transfer is needed.
Targeted advertising – If you have given your consent to advertising cookies or haven’t objected the use of Finnair’s legitimate interest to conduct targeted advertising or both, we share your personal data with our third-party partners that enable us to deliver targeted advertising through third-party channels and platforms. These third-party partners, which currently are Meta Platforms Ireland Limited, Google LLC and Sanoma Media Finland Oy, may act as joint controllers together with us and as independent controllers to whom your data is transferred for delivering you targeted advertising. Please note that when acting as an independent controller, these third-party partners may use your personal data for aggregation purposes and to infer and derive advertising-related segmentations and reports based on the aggregated data to be also used by other advertisers on the third-party platform.
If you are a user of Meta Platforms Ireland Limited’s services such as Facebook and Instagram, you can learn more about your privacy rights on those platforms on Facebook's website.
If you are a user of Google LLC’s services, you can learn more about your privacy rights on Google’s website.
If you are a user of Sanoma Media Finland Oy’s services, you can learn more about your privacy rights on Sanoma’s website (in Finnish).
If in any of our operations your personal data is transferred outside of the European Economic Area or the European Union, we will always use appropriate personal data transfer mechanisms and safeguards to ensure that your personal data is processed in accordance with applicable privacy and data protection laws. We also ensure that our ICT and other service providers do so and assess that our third-party partners implement similar, compliant practices to safeguard your personal data.
3.3.5. How We Retain Your Data
We retain your personal data for marketing communications purposes for so long as you have not opted out from receiving our marketing communications and content personalisation.
If you opt out, we will no longer send you marketing emails and you will no longer see our personalised advertisements on the third-party platforms, effective for emails immediately and for personalised advertisements within 24 hours.
Please note that we will retain certain data if required by law, or for our legitimate business purposes unrelated to marketing communications or content personalisation purposes.