1. Responsible party
We, Lufthansa Process Management GmbH (Dornhofstraße 34, 63263 Neu-Isenburg, Germany) (hereinafter also “we”), wish to inform you how your personal data is processed when you use our website www.lpm-services.com (hereinafter also “website”).
If you have any further queries regarding data protection in connection with our website or the services offered, please contact our data protection coordinator:
Data Protection Coordinator
Lufthansa Process Management E-mail: LPM_contact@dlh.de
2. Scope, purpose and legal basis of processing personal data
We collect and use personal data directly from our users and other sources (mentioned below) in the following situations:
2.1. Provision of the website and log file creation
By visiting our website, the system automatically records data and information about the user’s computer system each time the website is accessed. The following data (“technical information”) are collected:
(1) Information on the browser type and version used (2) The user’s operating system (3) The user’s Internet service provider (4) The user’s IP address (5) Date and time of access (6) Websites from which the user’s system accesses our website (7) Websites accessed by the user’s system via our website
The data are also saved in our system’s log files. These data are not stored together with other personal data of the user.
We collect and use this technical information for the purposes of (network) security (to for example ward off cyber-attacks), marketing and to better understand our users’ needs as well as to continuously improve our website and enable users to access the website from their computers.
The data are saved to log files to ensure website functionality. The data also help us improve the website and safeguard our information technology systems. The data are not analyzed for marketing purposes in this context.
Art. 6(1)(f) GDPR forms the legal basis for the temporary storage of the data and log files.
2.1.2. Tracking tools
We use the following tracking and (re)marketing tools on our website:
Our legitimate interest pursuant to Art. 6(1)(f) GDPR for the purposes of increasing the efficiency of our website and (direct) marketing is the legal basis for the use of the tools listed.
For further information on the individual tools, please check the Appendix.
2.2. Use of the services offered on our website
We offer a range of different services on our website. We must collect and process user or customer personal data in order to perform these.
You may have the option of subscribing to a free newsletter on our website. When you subscribe, the data from the input screen is sent to us and processed:
Title, first name, last name and email address
The following data are also collected when you subscribe:
(1) IP address of the computer accessing the website (2) Date and time of registration
No data are disclosed to third parties in connection with data processing for the distribution of newsletters. The data are used exclusively to distribute the newsletter.
We may process your data in connection with the newsletter in order to send news about topics from the Lufthansa Process Management world that we think are interesting. We also process and use the given email address for sending you personalized offers in connection with the newsletter.
Art. 6(1)(a) GDPR forms the legal basis for data processing following the user’s subscription to the newsletter if the user has given consent.
2.2.2 Contact via the contact form
On our website, you can send us a message by using the contact form. We collect and process the following data:
E-mail address, name
We use these data to process and answer your e-mail. For this purpose, your message will be forwarded to the responsible contact partner within our organization. This person will contact you based on the information you have entered in the contact form. Your data will not be forwarded to third parties.
Art. 6(1)(a) GDPR forms the legal basis for data processing following the user’s use of the contact form if the user has given consent.
2.2.3. Statistical analysis
There is a possibility that your data may be analyzed in a data warehouse to evaluate the preferences of our registered customers (“statistical analysis”) for the purposes of interest-led marketing, individual approaches, and continuous optimization of our business processes. We undertake this processing in order to acquire a better understanding of what our customers expect from us and to allow us to offer you communication that is tailored to you personally. This analysis also helps us with fraud detection, auditing and safeguarding security, which is why we perform this processing to protect our legitimate interests, Art. 6(1)(f) GDPR.
2.3. Our legitimate interest in processing personal data
If Art. 6(1)(f) GDPR forms the legal basis for the processing, our legitimate interests are, in addition to the purposes listed above:
To protect the company against material and immaterial damage
Professionalism (of our products and services)
Cost optimization (control and minimization)
2.4. Other processing commitments
If obliged to do so by law, we process personal data in order to meet duties of retention under commercial or tax law or to meet legal security requirements (such as Section 7 of the Aviation Security Act [LuftSiG]). For further information on retention periods, please refer to “Duration of the data processing”.
2.5. Obligation to provide personal data
The input fields which are mandatory to be filled out for performing the requested service are marked accordingly on the website. The input is mandatory because of either legal or contractual requirements.
3. Duration of the data processing
Your personal data are deleted as soon as they are no longer needed for the specified purposes. In certain circumstances, personal data are kept for the period of time during which claims against Lufthansa Process Management GmbH may be enforced (statutory limitation period of three to thirty years). Personal data are also saved to the extent that and for so long as Lufthansa Process Management GmbH is legally obliged to do so. Corresponding burdens of proof and duties of retention arise from, among others, the Commercial Code, Tax Code and Money Laundering Act. These prescribe retention periods up to ten years.
4. Right to object pursuant to Art. 21 GDPR
You have the right to object, on reasons relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.
The controller shall no longer process your personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or processing is necessary for the establishment, exercise or defense of legal claims.
Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
5. Disclosure of personal data to third parties
In order to offer you our products and services, based on our contractual obligations or in accordance with our legitimate interests, we may have to disclose your personal data to third parties internal or external to the Lufthansa Group. IT service providers are the only external recipients.
If we believe that your contact request is aimed at another Lufthansa Group company, we will forward your data within the Lufthansa Group to ensure that your request reaches the correct department.
Personal data may be transmitted to third countries or international organizations as part of this. For your protection and the protection of your personal data, appropriate safeguards are provided for such data transmissions as per and in accordance with legal requirements (particularly, the use of EU standard contractual clauses) or an adequacy decision has been issued by the EU Commission (Art. 45 GDPR).
For information on EU standard contractual clauses, please visit [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=DE]. The EU Commission provides the relevant information relating to its adequacy decisions at [https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en#dataprotectionincountriesoutsidetheeu].
A copy of the security precautions used may also be requested from LPM_contact@dlh.de
We are also legally obliged to provide personal data to German and international authorities, Art. 6(1)(c) GDPR together with local and international regulations and agreements.
6. Rights of the data subject
Lufthansa Process Management GmbH is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object, but also the following rights where the respective legal requirements are satisfied:
Right of access, Art. 15 GDPR
Right to rectification, Art. 16 GDPR
Right to erasure (“right to be forgotten”), Art. 17 GDPR
Right to restriction of processing, Art. 18 GDPR
Right to data portability, Art. 20 GDPR
To exercise your right, please email LPM_contact@dlh.de. In order to process your request and for identification purposes, please note that we will process your personal data in accordance with Art. 6(1)(c) GDPR.
You also have the right to lodge a complaint with a supervisory authority. The relevant supervisory authority for Lufthansa Process Management GmbH is:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Postfach 31 63
If you give your consent to us for processing your personal data, please note that you may withdraw this consent at any time.
If you gave this consent on the website, please visit the page where you originally gave consent or log in using your LH ID in order to withdraw consent in the settings.
If you have consented to receive our newsletter, you may withdraw this consent by using the “Unsubscribe” link in the newsletter.
In all other cases or if you have problems withdrawing your consent on the website, you can contact LPM_contact@dlh.de
Please note that your consent can only be withdrawn with future effect, and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis – e.g. to perform a contract.
8. Legal disclaimer
Lufthansa Process Management GmbH and its member firms and affiliates, including their perspective partners, principals, employees, agents and representatives make no representations or warranties about the accuracy, timeliness suitability or any other aspect of this site or any content on or accessed through this site for any purpose, all of which is provided „as is“ and „as available“ without any warranty of any kind. Lufthansa Process Management hereby disclaims all warranties and obligations with regard to the site or any content on or accessed through this site, including but not limited to all implied warranties and obligations of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Lufthansa Process Management GmbH, its member firms, affiliates, partners, principals, employees, agents and representatives be liable for any direct, indirect, incidental, special, exemplary, consequential or other damages whatsoever, without regard to the form of any action, including but not limited to contract, negligence or other tortious actions, arising out of or in connection with this site, any content on or accessed through this site, or any copying, display or other use thereof.
This site and its content are made available only to provide information about Lufthansa Process Management GmbH. We make no representation that this site or any content on or accessed through the site are appropriate or available for use in other jurisdictions. You are responsible for compliance with all applicable laws and regulations.
Lufthansa Process Management points out that the user is responsible for protection of its own soft- and hardware (e.g. anti-virus programs, firewalls …). In no event shall Lufthansa Process Management be liable for any damages that occur to hard- and software (including data) which might be caused by the use of this Website.
Minors should not transmit any personal data to Lufthansa Process Management websites without the permission of their parents or guardians. Lufthansa Process Management recommends all parents and guardians to show their children how to deal with personal data on the Internet in a secure and responsible manner.
10. Disclaimer and limitations of these data protection notices
These data protection notices only apply to processing for the website www.lpm-services.com. Other websites are not covered by these data protection notices and provide their own specific data protection notices.
Appendix – notices on the tracking and remarketing tools used
This site uses Matomo to analyze traffic and help us to improve your user experience. This is an open-source web analysis tool.
Matomo is processing the following personal data:
Location of the user
Date and time
Title of the page being viewed
URL of the page being viewed
URL of the page that was viewed prior to the current page
Time in local timezone
Files that were clicked and downloaded
Link clicks to an outside domain
Pages generation time
Country, region, city
Main Language of the browser
User Agent of the browser
The processing of personal data with Matomo is based on legitimate interests.
The processing of personal data with Matomo is based on explicit consent. Your privacy is our highest concern. That’s why we will not process any personal data with Matomo unless you give us clear explicit consent.
You can opt-out of Matomo Analytics at any time by clicking here (insert the Matomo tracking code here to remove consent).
For more information on the privacy practices of Matomo, please visit the Matomo Privacy & Terms web page: https://matomo.org/privacy-policy/