Brussels Airport Company NV (hereafter: “Brussels Airport” or “we”) values your privacy and Personal Data (as defined below) and therefore protects and processes your Personal Data only in accordance with the Belgian privacy law of 8 December 1992* , including changes brought about by the General Data Protection Regulation (GDPR)** .
* Wet van 8 december 1992 tot bescherming van de persoonlijke levenssfeer ten opzichte van de verwerking van persoonsgegevens.
** Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Brussels Airport App means the Brussels Airport application which can be downloaded for free in the relevant application store;
Data Subject means an identified or identifiable natural person, who can be identified, either directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Personal Data means any information relating to an identified or identifiable natural person;
Third Party means a natural or legal person, public authority, agency or body other than the Data Subject, Brussels Airport, processor(s) of Brussels Airport and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
Website means www.brusselsairport.be;
Websites means the Website and all other domain names owned by Brussels Airport, such as but not limited to www.brusselsairport.nl, www.brusselsairport.fr, www.bruxx.be, www.brusselsairport2040.be, www.brucloud.com and www.brucard.be.
4. Personal data we process and why we process it
Brussels Airport may collect several types of Personal Data from Data Subjects visiting the Websites and may store it on its servers. Such Personal Data may include:
- Direct identifiers (e.g. your full name)
- Contact information (e.g. your postal address, e-mail address, phone number);
- Information provided in helpdesk support inquiries;
- Electronic identifiers, i.e. IP addresses (i.e. a unique string of numbers that identifies each network connected device (e.g. laptop, tablet, smartphone) enabling the communication and exchange of information with other devices over an IP-based network, such as the Internet) to manage the Websites and ensure that relevant information is sent to your computer;
- Location information (based upon your IP-address).
If you are visiting one of our Websites which offers you the opportunity to register online and create an account, the following Personal Data may be collected:
- Direct identifiers (e.g. your full name);
- Indirect identifiers (e.g. your country, postal code, date of birth);
- Contact information (e.g. e-mail address);
- Personal characteristics (e.g. gender, language, travel preferences);
- Your profile picture.
You are offered the possibility to register through one of the social media channels on which you are active. In that case, Brussels Airport shall receive all of your profile information that you have publicly made available on such social media channel.
We shall not receive any Personal Data which is set to be private. To manage your privacy settings on your social media profile page, we refer you to the policy of the relevant social media channel.
We may also process general user data, such as most frequently requested pages, which shall not be linked to any identified user, in order to provide comprehensible Websites which directly address the needs of the general users. In the event we detect a common pattern, we may be able to place more targeted information on our Websites, which is mostly requested and viewed. This way we can further optimize the services we offer to you through our Websites.
Brussels Airport (i) collects, (ii) uses, and (iii) maintains the Personal Data provided by the Data Subject or collected by Brussels Airport for all purposes necessary to ensure the proper (technical) functioning of the Websites and/or the creation of an account.
In general, Brussels Airport collects your Personal Data for an overarching goal: offering each Data Subject that makes use of the Websites a safe, optimal and personalized experience. Dependent on whether the Data Subject makes intensive use of the Websites or relies on certain services, the collection of Personal Data may be more or less extensive.
Other purposes for data collection and processing of your Personal Data through the Websites may include:
- Providing you access to and participation on the Websites and the use of the services provided through the Websites, including customer service;
- Diagnosing technical problems and managing technical support and processing inquiries concerning the Websites;
- Commercializing the Websites;
- Direct marketing purposes, insofar Brussels Airport has obtained the explicit consent of the Data Subject hereto;
- Performing data analyses (including anonymization and aggregation of Personal Data);
- The operation, evaluation and improvement of the Website (including the development of additional products and/or services, enhancing and improving the current Websites, analysis of our Websites, quality control activities and performing internal business functions such as accounting and auditing);
- Protecting against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
4.2. Social Media
On the various social media channels on which Brussels Airport is active, and as enumerated here below, we provide offers, as well as useful information, facts and the latest news about Brussels Airport. You can also easily contact us through one of our social media accounts, participate in discussions, respond to posted content such as pictures, ask questions, or participate in any other way made possible by the social media channel used. For us, our social media accounts are an easy and quick method for keeping a close connection to our passengers and the expected and/or desired experience while travelling, as well as for quickly addressing any of their concerns.
Media channels we use, include:
We kindly request you not to post any (sensitive) Personal Data of yourself or others, such as a private e-mail address, date of birth, address, or telephone number, on these social media channels to avoid any possible abuse of such Personal Data, as it will become publicly available. We prefer that, if deemed necessary, you share such Personal Data through a private message or through e-mail. In the event that you share any (sensitive) Personal Data on a page of a social media channel that is publicly accessible, Brussels Airport reserves the right to delete such Personal Data in order to protect you from any possible abuse.
Brussels Airport shall solely use your Personal Data provided through the social media channels for the purpose of improving our customer service, and, where necessary, addressing your request.
4.3. Brussels Airport App
You can download the Brussels Airport App in the available application store of your mobile device for free. In order to be able to make use of certain services provided through the Brussels Airport App, we may require certain Personal Data from you, such as your location details and flight number. The Brussels Airport App shall also process the necessary information from your mobile device, such as your Media Access Control (MAC) address, device ID and IP address, in order to enable you to use the application. We will not link such information to any individual user data, thus Personal Data is not revealed.
We shall solely process your Personal Data through the Brussels Airport App for the purposes set out more in detail here below.
4.3.1. Providing services
My flights. You can add any of your scheduled flights on the Brussels Airport App in order to receive relevant information related hereto, such as the exact row number for check-in and baggage drop-off. If you consented to receive push notifications, we will be able to send you notifications relevant to your added scheduled flight.
Promotions. From time to time, we may offer you certain promotions, coupons and discounts through the Brussels Airport App, which you can use at the airport. We may process certain abovementioned Personal Data if necessary to be able to offer you such promotion, coupon and discount.
Where is my car? When you come to Brussels Airport by car, you can make use of our “Where is my car?” function, in which you can indicate in which parking lot, on what level and on what number your car is parked. We will store such information as a parking reminder in the Brussels Airport App, so you will never forget where you parked your car when you get back.
4.3.2. Location services
From and to Brussels Airport. If you have permitted the Brussels Airport App to make use of your location information, and you make use of the “from and to Brussels Airport” function, Brussels Airport may process your location details in order to calculate your travel time from where you are located to Brussels Airport, or from Brussels Airport to a location of your choice. In the event you have not enabled the use of your location information, you may manually insert your location to calculate your travel time to and from the airport. To determine your location and calculate your travel time, Brussels Airport may make use of an external service provider who shall be subject to what is set out in 6. Disclosure to Third Parties.
Brussels Airport shall not process your location details if you have not granted your permission. In the event you have granted your permission and wish to withdraw it, you can always change your preferences in the (location) settings of your mobile device.
iBeacons at the airport. Brussels Airport is equipped with iBeacons which send out signals to your mobile device when the Brussels Airport App has been downloaded and Bluetooth is activated. Your MAC address shall be processed in order to determine how long your mobile device is located in a certain area. However, we will not link such information to any individual user data, thus Personal Data is not revealed. In case you have enabled the Brussels Airport App to send push notifications, you may receive push notifications depending on the area where you are located at that particular moment.
4.3.3. Analyzing and optimizing the Brussels Airport App
Brussels Airport may also process general user data, such as most frequently requested links, which shall not be linked to any identified user, in order to provide a comprehensible Brussels Airport App which directly addresses the needs of the general users. In the event we detect a common pattern, we may be able to place more targeted information on our Brussels Airport App, which is mostly requested and viewed. This way we can further optimize the services we offer to you through our Brussels Airport App.
Brussels Airport (i) collects, (ii) uses, and (iii) maintains the Personal Data provided by you or collected by Brussels Airport for all purposes necessary to ensure the proper (technical) functioning of the Brussels Airport App.
You can subscribe to one of our online newsletters through our Websites to stay up-to-date with our latest news by providing your e-mail address. We may also give you the option to subscribe to our newsletter(s) through other channels, such as via subscription forms of campaigns and online contests. However, we shall always request you to explicitly opt-in and provide your consent to receive the newsletter.
We shall solely use your e-mail address for the purpose of sending you one of our newsletters to which you consented. You can always unsubscribe from the newsletter(s) via the link provided at the bottom of each newsletter mail.
If you live in the area of certain predefined postal codes, you shall automatically receive the Brussels Airport magazine, “Connect”. This magazine is similar to the local newspaper you receive from your municipality and has as a purpose to keep you up-to-date on the latest news of Brussels Airport, and any possible nuisance you may experience.
4.5. Campaigns and contests
Brussels Airport regularly organizes campaigns at the airport and/or online contests in which you can participate. Depending on the type of campaign and/or online contest, we may collect several types of Personal Data and may store it on our servers. Such Personal Data may include:
- Direct identifiers (e.g. your full name);
- Indirect identifiers (e.g. your date of birth);
- Contact information (e.g. postal address, e-mail address, phone number);
- Personal characteristics (e.g. gender, language, country);
- Electronic identifiers (MAC-address).
We shall only collect, use and process your Personal Data to determine the winner of the online contest and/or for providing you with a deliverable of a campaign held at Brussels Airport, for example a picture taken in the context of a certain campaign. We may however give you the opportunity to explicitly consent to and indicate that you wish to further receive information on other online contests and/or campaigns organized by Brussels Airport. If so, we shall solely keep your name and other relevant contact information, including all relevant information to make customized communication possible, e.g. correct salutation based on your gender or communication in your mother tongue.
When participating in an online contest, your name may be publicly announced on the relevant webpage to indicate that you are the winner of such contest. In the event that the winner of an online contest is published through social media, it is possible that you will be tagged in the winner announcement with your publicly available user name of the relevant social media channel. We may work together with external parties, such as airlines, who make it possible to (co-)organize a certain contest and/or campaign at Brussels Airport. We do not authorize these external parties to use or disclose your Personal Data, except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We guarantee that your Personal Data shall only be disclosed to such external parties insofar as necessary for them to perform their specific function. In the event that external parties co-organize a contest and/or campaign together with Brussels Airport, they shall be considered as joint controllers of your Personal Data. If this is the case, your Personal Data shall solely be transferred to such external parties with your knowledge, and for the sole purpose of the organization of the contest and/or campaign. Such external parties shall in any event be subject to what is set out in 6. Disclosure to Third Parties.
4.6. Your experience at Brussels Airport
4.6.1. Statutory obligations and tasks in the public interest
Protection of civil aviation. Following international and European legislation regarding civil aviation and related safety and security thereof, Brussels Airport carries out preventative security checks on passengers and baggage in the terminal. Brussels Airport has decided to outsource this task to specialized security companies. In the event any Personal Data of you is processed, it shall be done so for civil aviation security purposes.
Your boarding pass data shall be processed at the controlled access gates, i.e. the automatic boarding pass control, for the purpose of providing you legitimate access to the security restricted area of the airport. Access control checks shall also be performed on employees at Brussels Airport, whose badges shall be checked in order to gain access to the security restricted area of the airport.
Camera images. Your, as well as our staff’s, safety and security at Brussels Airport is very important to us. Therefore, we make use of surveillance cameras and CCTV cameras. We will process camera images for the purposes of safety and security, to improve (safety) procedures, for flow management at the airport, incident resolution and management of (damage) claims, management of the goods and the operational process of machines of Brussels Airport, and for access control.
We will not store the camera images for longer than thirty (30) days, unless an incident has occurred which can be resolved by means of the relevant camera images, in which case the images will not be stored for longer than necessary for incident resolution. Insofar as it is necessary to comply with statutory obligations, government bodies, such as the police and the courts, may receive camera images, which may include your Personal Data.
Automated border control. The Schengen Borders Code requires the border police to perform a reinforced identity check of every passenger leaving or entering the Schengen area, where appropriate by using technical devices. In the event that you travel outside the Schengen area, you have to enter through one of the automated border control gates, where your passport information and picture shall be verified by scanning your facial characteristics in real-time. If both your passport picture and facial characteristics match, you shall be able to proceed to your gate. The system shall store your Personal Data solely during the transaction for the purpose of border control and providing you access. The system is managed by Brussels Airport, in its capacity as processor, on behalf of the border police, who is the controller of these data.
Retailers. Retailers at Brussels Airport may ask to scan your boarding pass for different purposes. For example, to record whether a product was sold tax-free or taxable, which will depend on your destination, i.e. whether you travel within or outside the EU. As such retailers decide themselves for which purposes they collect your Personal Data, Brussels Airport shall not be responsible for the processing of your Personal Data by such retailers. In case you have any questions on this topic, we advise you to contact the relevant retailer directly. You can find the contact details of the retailers within Brussels Airport on our Website. Brussels Airport may however receive certain data from such retailers but solely for statistical purposes.
4.6.2. Optimisation of company processes and systems
In order to optimize Brussels Airport’s business processes, such as the baggage process and passenger process, and for the purpose of optimizing your travel experience at our airport, we may process your Personal Data. In case Wi-Fi and Bluetooth are enabled on your mobile device, we will track your passenger journey throughout our airport for statistical and analytical purposes, as well as for crowd management. If you do not wish to be tracked, you need to switch off your Wi-Fi and Bluetooth on your mobile devices.
Brussels Airport shall make use of infrared cameras and sensors to trace Wi-Fi and Bluetooth signals for the purpose of measuring the number of passengers at certain locations within a certain timeframe. This enables us to give you information on expected peaks, queues and waiting times at the airport. We shall only process the unique Media Access Control (MAC) address of your mobile and wireless device(s), which does not link to any individual user data, thus Personal Data is not revealed.
As a person passes a sensor, the active MAC address shall be linked between the several sensors set up in the airport to provide origin and destination data, as well as travel time. As concerns the infrared cameras, no images are made but merely the density of the crowd at a certain place and point in time is measured.
The sensors make use of encryption techniques such as one-way hash, SSL Encryption and re-hashing in order to ensure your privacy. For more information on the security measures taken to ensure your privacy, and the manner of processing of your Personal Data, we refer to the privacy guarantee of BLIP Systems (http://www.blipsystems.com/wp-content/uploads/2014/10/BlipTrack-Privacy-Concerns.pdf).
4.6.3. Supply of services and products
Passengers with reduced mobility. In case you have mobility issues and are travelling within Brussels Airport, you may apply for special assistance to help you move about the airport. You need to request this service at least forty-eight (48) hours in advance of your scheduled departure time through your airline or travel agent, who shall provide the relevant Personal Data directly to one of our external assistance providers in order to bring you to the gate in a wheelchair. For the purpose of providing you with the appropriate assistance, our external assistance provider shall process your full name, date of birth, flight number, contact information and health data, i.e. insofar this is necessary to provide you with the appropriate assistance. Brussels Airport shall not receive any of your Personal Data, and we therefor refer to your airline or travel agent for more information.
Welcome Center. In the event that you make use of our services at the information desk, it is possible that we process your Personal Data in order to be able to help you further. We shall always limit the amount of Personal Data processed to what is necessary to provide you with the requested service.
Lost and found. In the event that you have lost something at our airport, you can make use of our lost and found service. We will request you to fill out a contact form, in which you will be asked to provide your full name, email address, telephone number and a description of the lost item. In case you cannot collect the lost item yourself, you can send us an email with the full name of the person who will collect it for you. At the time of collection, we shall make a copy of your identity card in order to verify your identity and link it to the collected lost item, as well as to avoid any future possible misunderstandings. We shall in no event store your Personal Data, including the copy of your identity card, for longer as necessary.
iBeacons. Brussels Airport is equipped with iBeacons which send out signals to your mobile device when the Brussels Airport App has been downloaded and Bluetooth is activated. Your MAC address shall be processed in order to determine how long your mobile device is located in a certain area. However, we will not link such information to any individual user data, thus Personal Data is not revealed. In case you have enabled the Brussels Airport App to send push notifications, you may receive push notifications depending on the area where you are located at that particular moment.
4.6.4. Market surveys
When at the airport, it is possible that one of our external business partners approaches you to conduct a market survey. Such external market research companies shall process your Personal Data on our behalf, and we shall be in full control of what happens with your Personal Data.
Depending on the type of market survey, we shall process your age, postal code, gender, nationality, country of origin and/or means of transport used to come to the airport. We shall solely process such Personal Data for statistical purposes and shall take appropriate technical and organizational measures to de-identify your Personal Data, where possible.
We shall take appropriate technical, organisational and administrative measures against unauthorized or unlawful processing of any of your Personal Data or its accidental loss, destruction or damage, access, disclosure or use.
In the event of a personal data breach (e.g. breach of security of the Personal Data, or access by an unauthorized person) at Brussels Airport in which your Personal Data is involved, we shall take all necessary measures to mitigate any consequences of such personal data breach, and to avoid such breach in the future. We are required by law to notify you if the personal data breach is likely to affect your fundamental rights and freedoms and constitutes a risk to your privacy.
6. Disclosure to Third Parties
7. Data transfers to countries outside the EEA
In certain cases, Brussels Airport may transfer and/or store your Personal Data in countries outside the European Economic Area. However, in such cases, we guarantee that the transfer shall take place in accordance with the relevant legal requirements and we ensure that the third country shall be able to guarantee an adequate level of protection of your Personal Data. The EU standard contractual clauses shall be utilized where necessary, and appropriate data transfer agreements shall be concluded.
8. Your rights as a data subject
We shall process your Personal Data solely in a fair and lawfully manner, which includes that the Personal Data provided to us shall only be processed for the abovementioned explicit and legitimate Purpose(s). We ensure that the processed Personal Data is adequate, accurate, relevant and not excessive. However, you, as a data subject, are also granted several rights relating to the Personal Data you have shared with us, so that it is you who will remain in full control of your Personal Data.
My right of access
If you are concerned about the Personal Data that is being processed of you, or if you have any questions regarding your Personal Data, you have the right to request access to the Personal Data which Brussels Airport processes or stores about you.
My right to correct inaccurate Personal Data
We commit to keeping all of your Personal Data accurate and up-to-date, however, it is possible that sometimes we miss some updates. Therefore, you are granted the right to request us, free of charge, to rectify and correct any inaccuracies or incompleteness of your Personal Data.
My right to erasure
Under certain predefined circumstances, you shall have the right to request the erasure of your Personal Data without undue delay. It shall be assessed by Brussels Airport on a case-by-case basis whether or not your request qualifies for the erasure of your Personal Data. In the event your request falls under one of the predefined circumstances, and no exceptions as set out in the GDPR apply, your Personal Data shall be erased out of the internal systems at Brussels Airport. However, it is possible that the deleted Personal Data remains temporarily stored in our Brussels Airport’s back-up system. We shall take all reasonable steps to erase all Personal Data to the maximum extent possible.
Closely related to your right to erasure, you shall also have the right to be forgotten in the event that your Personal Data has been made public. Your Personal Data shall then be erased out of the internal system, and reasonable technical and organisational measures shall be taken to erase all links to, and copies or reproductions of, the Personal Data.
My right to restrict data processing
In certain predefined circumstances, you may request Brussels Airport to temporarily halt and restrict the processing of the Personal Data in question. It shall be assessed by Brussels Airport on a case-by-case basis whether or not your request qualifies for the restriction of processing. In the event that your request falls under one of the predefined circumstances, Brussels Airport may still store your Personal Data, however any other further processing of your Personal Data shall be restricted and may only be performed either with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.
In the event that the processing of your Personal Data is restricted following your request, we shall inform you before such restriction of processing is lifted.
My right to object to data processing
In certain predefined circumstances, you may object to the processing of your Personal Data by Brussels Airport. This is in short when the processing is based upon public interest or legitimate interest, when the Personal Data is processed for direct marketing purposes, or when the Personal Data is processed for statistical purposes. It shall be assessed by Brussels Airport on a case-by-case basis whether or not your request to object to data processing meets the requirements.
We may solely use your Personal Data to contact you through mail for direct marketing purposes in the event that you have explicitly consented hereto. If you have consented hereto in the past, and you no longer want to receive suggestions and/or direct marketing through mail, you may at any time oppose to such processing and unsubscribe from the mailing list.
My right to data portability
In the event that your Personal Data is processed on the basis of your consent or on the basis of a contract, and the processing is carried out by automated means, you have the right to receive all your Personal Data in a structured, commonly used and machine-readable format. Where technically feasible, you may also request us to transmit such Personal Data directly to another controller without any hindrance insofar this does not adversely affect the rights and freedoms of others.
My right not to be subject to automated individual decision-making, including profiling
In relation to your right to object to data processing, you shall have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects for you, or similarly significantly affects you. However, you shall only have this right in certain predefined circumstances, and it shall be assessed by Brussels Airport on a case-by-case basis whether or not your request is eligible.
Automated processing is to be understood as processing performed by machines without human intervention, such as direct marketing, targeted advertising and e-recruitment processes which are performed electronically rather than by a human and based upon which decisions are made. In other words, in case of individual automated decision-making, there is no (significant) human intervention which could correct possible outcomes.
Profiling, on the other hand, is to be understood as the automated processing of your Personal Data to evaluate certain personal aspects (e.g. performance at work, personal preferences, interests, behaviour, location, movements) relating to you, in particular to be able to categorize you on the basis of your Personal Data. Based on these categorizations, (automated) individual decisions can then be made. Profiling shall be subject to the right not to be subject to automated individual decision-making in the event that the decision-making happens fully automated, without any (significant) human intervention which could correct the possible outcomes.
How can you exercise your rights?
9. Data retention and deletion
We shall not retain your Personal Data for a period longer than necessary for the Purpose(s) for which they have been collected or for which they will be further processed. The retention of certain Personal Data may be subject to a retention period as determined by law, which Brussels Airport shall be obliged to adhere to.
10. Third Party websites or applications
Brussels Airport Company NV
Auguste Reyerslaan 80
Last updated: 18/05/2018