(Last updated: 12 March 2021 – v1.0)
The purpose of this full Privacy Notice (“Privacy Notice”) is to describe our Chatbot’s data processing.
WIZZ Air Hungary Ltd. (seat: Laurus Offices, Kőér street 2/A, Building B, H-1103, Budapest, Hungary; “Wizz Air”, “we”, “our” or “us”).
What is the Purpose of Processing the Data?
We will use your data for the purposes below:
1) Responding to your queries and requests: the purpose of processing your personal data is to respond to your queries and requests to us; for this purpose, we rely on our legitimate interest.
2) Improving our Chatbot: we may process your data based on your consent to analyse your conversations with our Chatbot and improve the natural language processing algorithms. Consequently, it helps us to converse more naturally with you.
3) Chatbot marketing messages: if you consent to us, we may send you direct electronic massages, including surveys and other electronic marketing communication regarding the Chatbot to improve our services.
The provision of your personal data is voluntary. However, if you do not provide your data, you may not be able to use our services.
What Personal Data We Process about you?
For the purposes outlined above we process the data categories indicated below:
A. Identification data: name, surname, gender, email address, profile on social networks, photo.
B. Conversation content: including details of your question, inquiry, or our communication with you.
C. Survey data: your feedback to our surveys and questions and other marketing communication with you.
The legal basis for processing your personal data
To process your personal data, we may rely on the legal bases below:
- Your consent provided to us under the EU Regulation 679/2016 ("GDPR") Article 6 (1) a) (“Consent”).
- The processing of your personal data is possible based on our legitimate interest under the GDPR Article 6 (1) f) (“Legitimate Interest”).
Wizz Air has a legitimate interest in processing data to respond to your questions, inquiries because it is critical to engage with Users if they have queries to maintain their confidence in Wizz Air. If Users have contacted Wizz Air with a question (or complaint), it is reasonable for them to expect that their data will be processed to facilitate a response.
We may process your personal data for the purposes and legal bases indicated below:
Purpose of data processing
Categories of personal data processed
|Responding to your queries and requests|
- Identification data
- Conversation content
|Improving our Chatbot||Consent|
|Chatbot marketing messages||Consent|
How long do we keep your personal data?
Personal data is stored by us, but only as long as necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the information was obtained. The personal data will be removed from our records or properly anonymized when it is no longer needed.
We may store your personal data collected while interacting with our Chatbot up to one year. If we process your personal data based on your consent, we will process and store your personal data until your consent is withdrawn.
Who may access to your data?
Within Wizz Air employees with appropriate authorization may have access to your personal data on a “need-to-know” basis. We may engage other persons, third parties as data processors to provide services to us and courts, government bodies or other authorities may require us to disclose your data them.
- Service providers: we use externally provided IT-systems or services provided by third party vendors as a support to internal processes.
|Destygo (Mindsay)||131, avenue Parmentier, 75011 Paris, France||Chatbot development and operation.|
|Facebook Ireland Ltd.||5 Hanover Quay 299136 Dublin, Ireland||Data storage and Messenger|
|Amazon Web Services||38 Avenue John F. Kennedy, L- 1855 Luxemburg||Data storage|
|DeepL||DeepL GmbHMaarweg 16550825 Köln, Germany||Translation Services|
|Google Ireland Ltd.||Google Building, Gordon House, Barrow Street, Dublin 4, Ireland||Translation Services|
|salesforce.com EMEA Limited||Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, United Kingdom||CRM and LiveChat function|
- Wizz Air Group: your personal data may be shared within the Wizz Air Group if needed. For more information about Wizz Air Group, please click https://wizzair.com/en-gb/information-and-services/about-us/company-information.
- Government authorities and enforcement bodies: we may share your personal data with government authorities or enforcement bodies such as regulatory authorities, upon their request and only as required by the applicable law or to protect our rights or the safety of our customers, staff and assets
Personal data may be provided to parties that are located outside the European Economic Area ("EEA"). In such cases, we will ensure that the personal data is subject to measures (such as Standard Contractual Clauses for data transfers) that provide an equivalent level of protection as provided by data privacy laws in the EU (such as the EU General Data Protection Regulation; GDPR).
By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Article 46(5) GDPR or other adequate means, we have established that all other recipients located outside the EEA will provide an adequate level of data protection for the personal data and that appropriate technical and organizational security measures are in place to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
You are entitled to exercise your rights indicated below:
(i) Right of access: You have a right to ask whether or not we have personal data about you and, if that is the case, request information on what personal data we have.
We may request additional information from you for identification or for further copies requested by you, we may charge a reasonable fee based on administrative costs.
(ii) Right to rectification: We are required to rectify inaccurate personal data, or to complete personal data that is incomplete, on request.
(iii) Right to erasure (right to be forgotten): We are in some circumstances required to erase personal data on request by the data subject.
(iv) Right to restriction of processing: We are in some circumstances required to restrict our use of personal data on request by the person concerned. In such cases, we may only use the data for certain limited purposes set out by the law.
(v) Right to data portability: You may have the right to receive your personal data to which we have access, in a structured, commonly used and machine-readable format and such persons may then have a right to transmit those data to another entity without hindrance from us.
(vi) Right to object:
You have the right to object to the processing of your personal data for any reason relating to your situation, and in this case, we may not be able to process your personal information. If you have the right to object and the exercise of this right is justified, your personal data in concern will not be further processed for the purposes of the objection. The exercise of this right does not entail any costs.
If you consider that your privacy and data protection rights have been infringed, you may contact the competent data protection authority located in the European Union’s relevant Member State where your habitual residence, place of work or place of the alleged infringement is or the Hungarian National Data Protection and Freedom of Information Agency (Nemzeti Adatvédelmi és Információszabadság Hatóság – NAIH; seat: H-1055 Budapest, Falk Miksa str. 9-11.; website: www.naih.hu; phone: +36-1-391-1400; email address: email@example.com; fax: +36 1 391 1410.
Wizz Air’s Data Protection Officer
If you have any further questions about the Privacy Notice or how we handle your personal data please contact us by sending your query to us by e-mail or by writing to our Data Protection Officer at Wizz Air Hungary Ltd., Laurus Offices, Kőér street 2/A, Building B, II-V., H-1103 Budapest (or firstname.lastname@example.org).