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Airshoppen Taxfree

Privacy Policy


Thomas Cook Group understands and respects the importance of protecting your personal data.

This Privacy Policy sets out the basis on which we process the personal data we collect from you, or that you provide us with, relating to your relationship with us as a customer or potential customer. 

This data may be collected via our websites (“sites”), our contact centre, our mobile applications (“apps”) or our social media channels (hereinafter referred to jointly as our “services”). Please read the following information carefully.

When you make a purchase or otherwise provide us with your personal data, we may transfer, store or process this data as specified below. We take all reasonable precautions to ensure that your data is processed securely and in accordance with this Privacy Policy.  If you do not feel able to accept these terms of use, you should not use the site or download material from it.

To whom does this Privacy Policy apply:

This Privacy Policy applies to personal data processed by Thomas Cook Airlines Scandinavia A/S, which is the legal entity that delivers the services in Airshoppen.

The organisation operates the following websites:

airshoppen.dk, airshoppen.se, airshoppen.no, airshoppen.fi, airshoppen.de, airshoppen.be, airshoppen.nl, airshoppen.co.uk, airshoppen.com, atlantic.airshoppen.com, thomascookairlines.dk.

What types of personal data do we collect about you and why do we collect it:

We collect personal data concerning you and anyone else you include in your booking.  The types of data we collect are the information you personally provide us with, that we collect from you or take note of concerning you, or that we collect from third parties.

Personal data you provide us with

(a) When you make a purchase, we may ask you for your name, address, email address, and phone number. This is data that we need to collect in order to arrange the services you request us to perform.

(b) If you participate in a competition or campaign, fill in a questionnaire or customer satisfaction survey or report a problem with one of our services, we collect your name and relevant contact information for the purpose of offering you the best possible customer service, customer experience, and customer satisfaction.

(c) If you contact us in order to make changes to or add options for your flight, we will keep a record of your email or other correspondence in our systems to ensure you receive the best service on your trip. If you contact us by telephone, we may monitor and/or record your call for training and customer service purposes.

(d) If you fly to countries where Advance Passenger Information System (APIS) information is required, we will ask you to enter your passport information before you enter that country. We collect this data because we have a legal obligation under international law to transmit this advance passenger information prior to departure to the country of destination.

In order to ensure that this information is up to date, accurate and complete, please be sure to let us know if something needs to be changed.

Personal data we collect and/or note about you 

Based on your previous use of our services and activity on our website, social media channels or interaction with our contact centre, we collect the following personal data about you:

(a) We collect details about your visits to our sites and apps (including, but not limited to, traffic data, location data, and weblogs) where this is required for our own purposes or some other purpose, and from the resources you access. We may utilise technical services provided by third parties, e.g. Google Analytics, in order to administer our services.

(b) We collect details about the website(s) you visit prior to linking to our sites, the pages you visit on our sites and the time spent on each page.

(c) We may collect data regarding your computer (or mobile device/tablet) – including, where possible, your IP address and operating system, your device's location, your browser type and cookie IDs – for system administration and marketing purposes (both our own and third-party advertisers to whom we provide advertising services) and to report aggregated information to our advertisers. These is statistical data relating to our users’ browsing behaviour and patterns, and none of the reports we pass on identify individual users.

Personal data obtained from other sources 

We may also obtain personal data from third parties who collect data about you on our behalf.  This includes:

(a) If you inform a third party that you wish to receive marketing messages from Airshoppen, your contact details and marketing preferences will be securely transferred to us.

(b) If you book a trip through a third-party travel arranger, certain personal data that is relevant to your booking (your name, email, booking number and address, email address or any special requirements you may have) will be transferred to us so that we can provide the services you have requested/booked.

Where do we store your data and who do we share it with?

Your personal data is stored in a combination of our own systems and systems at the suppliers we engage in order to provide our services. 

When you provide us with your personal data, it is necessary for us to send some data to be processed and stored with relevant third parties, for example, i) the technical partners who administer the services we provide, airports, and ground handling agents so that they can deliver the arrangements and assistance you require; ii) third parties in connection with completed questionnaires or customer feedback.

Some of these third parties may be located outside the European Economic Area (“EEA”). Organisations based outside the EEA may not be subject to the same level of data protection controls as those in the UK and EEA.   We will always try to avoid transferring your data to third parties outside the EEA unless either:

(a) your personal information is covered by one or more relevant legal safeguards. Such safeguards may include standard contractual clauses in a form approved by the relevant supervisory authorities, or that our suppliers have signed an independent privacy plan approved by the relevant supervisory authorities (such as the US Privacy Shield plan), or

(b) the transfer of your personal data is necessary for us to fulfil a contractual obligation to you.

In order for you to travel abroad, we may need to provide certain of your personal data to public authorities or other agencies, such as those responsible for immigration, border control, security and anti-terrorism.  Where we are not required to provide data to such authorities, where appropriate we may exercise our discretion in assisting them in detecting and preventing criminal activity.

We may disclose your personal data to any of our group companies for business purposes (these business purposes include storing your data on central/shared systems for managing bookings and customer support in destination countries). For the purposes of this policy, our group companies means our subsidiaries, our parent holding company and its subsidiaries.

We may disclose your data to relevant third parties in order to detect and prevent fraudulent payments or bookings.

How do we use your data when we deliver our services to you:

In order to provide our services to you, we use the data at our disposal in a number of ways.  We process your data either because it is necessary for us to do so in order to fulfil the terms of a contract entered into by you, or because we have legitimate business reasons to do so. 

We process your personal data in order to perform the following activities that are necessary in relation to a contract that you have entered into or because you have requested us to do something so that you can enter into a contract:

(a) Internal administration of your purchase and external communication of your purchase to our suppliers to ensure that the services you have requested are arranged.

(b) To communicate with you regarding your booking or purchase, including sending confirmations and relevant documentation.

We may use and process your personal data as specified below when it is necessary in order for us to perform activities that fall within our legitimate business interests:

(1) To prepare you customer experience:

(1a) To enable you to participate in interactive features on our sites and apps when you choose to do so.

(1b) To ensure that content from our sites, apps and booking systems are presented in the most efficient manner for you and for your device.

(1c) To notify you of changes to our service.

(2) To protect our companies from financial loss:

(2a) For debt collection or credit checks

(2b) For verification of payment cards (including use of systems such as Google reCAPTCHA on some of our sites to ensure that only genuine purchases are made).

(2c) To detect and prevent fraudulent or criminal activity.

(3) To promote our business and to improve our products and services:

(3a) You can object to and unsubscribe from receiving online marketing information, an option that will be included in any marketing announcement we send to you.  For further information, please refer to the section, 'When and how do we use your personal data for marketing purposes?’.

(3b) To contact you if you make an inquiry via our website but do not finish a booking, to check if there was a problem or if you need help to complete your booking.

(3c) For internal investigation/analysis to improve the quality of our services and products and to develop new products, by:

(i) Inviting customers to participate in surveys or customer/business discussion groups.

(ii) Using aggregated customer data to make informed decisions based on an analysis of customer booking/purchase trends and behaviours.

(3d) To contact you with targeted advertising delivered online through social media and other platforms operated by our own and other companies. You may receive advertisements based on data concerning you, either that we have delivered to the platform or because the platform has identified you as having characteristics that correspond to those specified by us. For further information, please refer to the help pages on the platforms where you receive the advertisements:

(i) In order to obtain more information about you by sharing your personal data with technology companies or platforms that may store data about you and can match their registrations with our own.  Either we or these companies may use cookies to match the personal data we hold concerning you (see also our Cookies Policy).

We use this information in two ways:

(a) We identify links between your attributes and your behaviours and market to others with the same attributes, in our direct marketing campaigns and through targeted advertising delivered through our Sites, Apps or third party platforms including social media channels.

(b) We tailor and personalise our interactions with you to make them more relevant to your interests. These interactions include your journey around our Sites and the content that appears on it and marketing communications we send or show to you in our direct marketing campaigns and through online targeted advertising described in the paragraph above. Please see ‘How we personalise marketing to you for more information;

(4) To support any potential business sale or acquisition:

(4a) If we sell or buy a company or asset, we may disclose your personal data to any potential buyer or seller of the business or asset in question.

We may use and process your personal data as stated below when we consider it to be in your vital interests that we do so:

(5) To assist you or make sure that you receive assistance from third parties in the event of an accident or emergency.

We may use and process your personal data as stated below when we have your consent to do so:

(6) To assist you or ensure that you receive assistance from third parties where you have special requirements regarding medication, health or diet.

(7) To send you marketing correspondence about our products and services, where we have requested your consent to do so. For further information, please refer to the section, 'When and how do we use your personal data for marketing purposes?’.

We may use and process your personal data as stated below when we have a legal obligation to do so:

(8) For the establishment, exercise or defence of disputes and legal claims. This may include proactively contacting you if we need to resolve any problems you experience or have experienced with a booking/purchase.

When and how do we use your personal data for marketing purposes?

Here, you can learn more about our marketing activities, including when and how we might contact you and how you can opt out of receiving marketing communications.

If you have made an enquiry or completed a purchase on one of our sites or through our contact centre, your personal data may be used by us to contact you in the manner permitted by law, i.e. by post, via electronic communications and/or by telephone, with information and offers related to products or services available for you to book or purchase through Thomas Cook. We will only do so if you have not unsubscribed from such marketing communications at the place where we collected your contact details.

If you have not yet made an enquiry or completed a purchase, we will only send you information and offers via email or text message if you have expressed a desire to receive such marketing communications, either directly through us or by informing a third party that you wish to receive marketing communications from us.  

We will not send your contact details to any third party without your express permission unless it is to one of our business partners that contributes to the delivery of Thomas Cook services or products, so that the third party in question can contact you or send you marketing communications. 

How we personalise our marketing communications with you?

In an attempt to make sure that our marketing communications and advertisements are relevant to you, we work with third parties to offer a better experience for customers and potential customers.

Using new technologies and with the help of advertising agencies and marketing activation platforms (which may include companies such as Dentsu Aegis Network and Converto Inc), we may use your personal data in the following ways:

(a) to try to ensure that all marketing communications we send to you relate to offers of products or services that are likely to be of interest to you.

(b) to tailor and register our digital marketing (such as our banner ads) and links from websites belonging to our marketing partners. This digital marketing may include marketing related to Thomas Cook or marketing related to third parties to whom we provide advertising services.

Our business partners and advertising networks (including Google DoubleClick for Publishers) may also provide you with advertisements on our sites.  We permit third parties to collect data about your online activities via cookies and other technologies. Third parties may include other Thomas Cook businesses or our suppliers/business partners, which will collect data when you view or interact with an advertisement on one of our sites and advertising networks.  We also collect data about your online activities via cookies and other technologies when you use websites other than our own, so that we can deliver advertising services to third parties. Using this technology, we may show you an advertisement related to a third party on other websites based on your page visits and other behaviour when you visit our sites.

The data collected by these third parties may be used to predict your preferences or interests, and to display advertisements on our sites or across the web that are relevant to those perceived interests. Please refer to our Cookies Policy for further information.

What to do if you do not wish to receive marketing communications from us:

We completely understand that you may not want to hear from us, and that’s fine. Opting out or unsubscribing is easy.

You always have the right to ask us to refrain from using your personal data for marketing purposes. You can exercise your right to prevent such processing by selecting the 'no marketing' option on the forms we use to collect your data. You can also exercise this right at any subsequent point in time by sending a request to unsubscribe to Customer Services, Airshoppen, Thomas Cook Airlines Scandinavia A/S, Hangar 276, 2791 Dragør, Denmark.

Your rights with regard to any personal data concerning you that we may hold:

Under GDPR and the Danish Data Protection Act, you have a number of rights in relation to your personal data.

Your right to access to your personal data

In many cases, you have the right to request access to data.  This means that you can request access to the data we store about you.  If we agree to transfer your personal data either to you or to others on your behalf, we will do so free of charge.

We may ask for proof of identity and sufficient information about your interactions with us to allow us to find your personal data.  You will be required to provide this information before we provide a copy of any personal data we hold concerning you to yourself or another person on your behalf. We are not able to provide you with a copy of your personal data if the data in question concerns other individuals or if we have legal grounds to withhold the data. 

See the ‘How to contact us' section if you need to make a request for access to your data.

Your right to rectification and updating of your personal data

It is important to us that your personal data is accurate and we employ methods that make it easier for you to review and correct the data we hold concerning you.

If you change your name, address or email address, or you discover that any of the other data we store is inaccurate or outdated, please let us know us by contacting our customer service team here.

Your right to withdraw your consent

If the legal basis for our processing of your personal data, as specified in the above section ‘How do we use your data when we deliver our services to you?’, is consent, you retain the right to withdraw that consent at any time.  If you wish to withdraw your consent to receiving any kind of marketing communication to which you have previously consented (see the section on “What to do if you do not wish to receive marketing communications from us” for further details), please contact our customer service team here. Please note that if you ask us to stop processing this data, we may not be able to deliver all or any of the services you have requested. 

Your withdrawal of consent for our processing of your personal data does not negate the legality of our processing prior to the withdrawal of consent.

Your right to object to processing of your personal data and not to be subject to a decision based solely on automated processing

Where processing of your personal data is based on our legitimate interests, you have the right to object to our processing of your personal data for such purposes by sending an email to the address given at the end of this Policy. With the exception of purposes for which we can demonstrate compelling legitimate grounds for continuing to process your personal data, we will cease processing in accordance with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights pursuant to applicable data protection legislation, we will permanently stop using your data for these purposes. Otherwise, we will inform you of the compelling legitimate grounds for our continued processing of your data.

Your right to the erasure of your personal data or to restrict processing

Under certain circumstances, you have the right to request the erasure of your personal data from our systems by sending an email to the address given at the end of this Policy. Provided that we have no current legal basis for continuing to process and store your personal data, we shall take all reasonable steps to fulfill your request.

You may also request that we restrict the processing of your personal data when you believe that we have no legal basis for doing so, and where you have objected to processing and our investigation of the matter is in progress, or you have requested that we continue to store your personal data because you require it for the establishment, exercise or defence of legal claims.  Where processing has been restricted as above, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person. 

Your right to data portability

If the legal basis for our processing of your personal data, as specified in the above section ‘How do we use your data when we deliver our services to you?’, is consent or we need to do so in order to meet our contractual obligations to you, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format.

You may also request that we transmit this data to another controller, and we will do so where this is technically feasible. We are not able to provide you with a copy of your personal data if the data in question concerns other individuals or if we have legal grounds to withhold the data.

How to contact us:

Any requests for access to your personal data should be addressed in writing to:

Legal & Compliance Dept.,

Thomas Cook Airlines Scandinavia A/S

Airshoppen 

Hangar 276

2791 Dragoer

Denmark

You can also request access by sending an email to our data protection officer Stephanie Troßbach: gdpr@thomascook.dk 

Once you have submitted your request and provided us with the necessary information (including proof of identity), we will begin a search for the personal data we hold concerning you and then have 30 days to respond to your request.

Submitting complaints

Please don’t hesitate to contact us if you have a complaint and we will do our utmost to resolve any issues or concerns you may have. You have the right to appeal to the relevant supervisory authority for data protection when you feel that your legal rights have been infringed.

If you would like to contact us regarding this Privacy Policy, please email or write to Thomas Cook, Legal & Compliance using the contact details above.

Storage of your personal data:

Once you have made a purchase with us, your personal data will be stored to ensure that we are able to provide you with the best possible customer service.  We also store your personal data to meet our legal and auditing obligations.

How do we protect your personal data?

The transmission of data over the internet is never completely secure and, while we do our best to protect your personal data, we cannot guarantee security when you transfer data to our sites. You therefore transfer data at your own risk. Once we have received your data, we take all reasonable precautions to ensure the safe storage of your personal data and to prevent unauthorised access to it.  All personal data you provide us with is stored on our secure servers.  All payment transactions are encrypted using SSL technology.

What happens when you follow a link from our website to a third-party website?

Our sites contain links to other websites that have their own privacy policies. 

Our sites contain links to and frames from websites belonging to our head office, suppliers, advertisers and other third parties. You can see when a third party is involved in the delivery of a product or service you have requested, as the third party's name appears alongside our own. If you follow a link or otherwise use one of these other websites, please be aware that these websites have their own privacy policies and that we cannot be held liable for these policies or for those third party websites. You should always check these policies before submitting personal data to these websites.

We reserve the right to update this Privacy Policy at regular intervals.

OCTOBER 2018