Privacy policy

Latest update: 23 May 2018

In this Privacy Policy we describe how Copenhagen Airports A/S (CPH) processes your personal data. The Policy supplements, but does not substitute, any other policies or terms and conditions laid down with respect to the use of individual services provided by CPH.

It is essential to CPH that you feel secure about our processing of the personal data that we obtain about you when you are at the airport, register as a member of CPH Advantage, sign up for or use one of our services, among other things.

You can also read our cookie policy here: CPH.dk/en/cookie-policy

If you are the holder of a CPH ID card, this following privacy policy applies.

Data controller

Your personal data are processed by Copenhagen Airports A/S, Box 74, Lufthavnsboulevarden 6, DK-2770 Kastrup, Denmark as data controller.

Data protection officer

CPH has appointed a data protection officer (DPO), and you are welcome to contact our DPO with any questions or other queries you may have about our processing of personal data. You can contact our DPO at privacy@cph.dk.

Mandatory information

Information marked * is mandatory. If you do not disclose such information, the consequence is that CPH will not be able to provide the services you request.

Your rights

You are, of course, entitled to request access to, rectification or erasure of any personal data about you that CPH processes. You also have the right to object to the processing of your personal data and to have the processing of your personal data restricted. If you are not satisfied with the way we process your personal data, you naturally also have the right to file a complaint with the Danish Data Protection Agency.

In particular, you have an unconditional right to object to processing of your personal data for direct marketing purposes. If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing of data before your withdrawal. You have the right to receive the personal data you have provided in a structured, commonly used, machine-readable format (data portability).

These rights may be subject to conditions or restrictions. Accordingly, you may not have the right to data portability in a given case – it depends on the specific circumstances of the processing activities.

Data collected from other sources

When we collect data from other sources than yourself, such source(s) may be:

  1. Online sources, such as publicly accessible social media.

Privacy policy updates

We will make changes to this Privacy Policy as required. You can see this by checking the date at the top of the page. In case of significant changes to the Privacy Policy we will inform you directly about the changes and the consequences hereof.

By clicking the icons below, you can see the processing of personal data that applies to the various parts of CPH. 

The policy applies to the following areas of CPH:

1. CPH ADVANTAGE

 

CPH collects information about you as a CPH Advantage member. The below information is a supplement to the general terms and conditions applicable to CPH Advantage, which are available here.

1.1 The personal data processed in CPH Advantage is the following:

  • Name*
  • Address*
  • E-mail address*
  • Date of birth*
  • Gender*
  • Telephone no.*
  • Purchase history*
  • Preferences
  • CPH Advantage membership no.*
  • Information collected via cookies at CPH.dk and via CPH App
  • Licence plate no.

1.2 Purpose

The purpose of processing data is to maintain your CPH Advantage membership, including improving our knowledge of you (profiling), among other things to enable us to send you relevant marketing material, for example in connection with offers, campaigns and competitions.

1.3 Basis of processing

Data in CPH Advantage are solely used subject to your consent in accordance with Article 6(1)(a) of the General Data Protection Regulation (GDPR). Naturally you have the right to withdraw your consent at any time.

1.4 Recipients

In certain instances, CPH will disclose personal data collected in connection with your relations to CPH Advantage. Data may be disclosed to:

  1. suppliers with whom we collaborate, including suppliers of technical support and operation of our services, social media for marketing purposes; or
  2. social media with regard to our marketing; or
  3. business partners such as shops, restaurants, airlines and our partners located in or outside CPH, in connection with orders, sales or the performance of other services; or
  4. if CPH has been ordered to disclose information in consequence of a court decision or if required under applicable law.

1.5 Erasure

Personal data are stored, as a minimum, for the duration of your membership of CPH Advantage. When you cancel or resign your membership of CPH Advantage, your data are erased. The personal data processed by CPH will be erased within 12 months of your cancellation/resignation. Before erasure, the data may be anonymised for statistical use in connection with CPH Advantage.

2. PARKING

 

CPH collects data on you in connection with your use of CPH’s car parks. The below information is a supplement to the general terms and conditions applicable to CPH Parking, which are available here.

2.1 The personal data processed in CPH Parking are the following:

  • Name*
  • E-mail address*
  • Telephone no.*
  • Country and postcode*
  • Licence plate no.*
  • Parking location, parking period and booking no.*
  • Advantage membership no.
  • Eurobonus no.
  • Brobizz no.
  • Payment method, including credit card information*
  • Disability badge no.
  • Information about your car for administrative purposes, e.g. collection and servicing of car

2.2 Purpose

The purpose of processing data is to perform/manage your agreement on/purchase of parking at CPH and for statistical purposes.

2.3 Basis of processing

Data processed in connection with the ordering of parking at CPH are processed on the basis of Article 6(1)(b) of the GDPR, as such data are necessary for the conclusion and performance of the agreement with you on purchase of parking at CPH and for the establishment or defence of any legal claims.

2.4 Recipients

CPH will disclose to CPH's business partners personal data collected in connection with your ordering of parking only when necessary, including if you have ordered valet parking or extra services, such as servicing or cleaning of your car. In case of non-payment, CPH may disclose information to our debt-collecting agency.

2.5 Erasure

Data collected in connection with your ordering of parking at CPH will be erased immediately upon performance of the parking agreement, including information about/photographs of licence plates. Some data are processed for up to five years after your parking at CPH, plus the current year, because CPH is required to store such data under the rules of the Danish Bookkeeping Act.

3. WIFI - CPH HOTSPOT

 

CPH collects and uses information about you when you use CPH’s wireless internet CPH Hotspot (WiFi). The general terms and conditions applicable to using CPH Hotspot are available here.

3.1 The following data are collected from your device (computer, tablet, cell phone or other terminal equipment):

  • E-mail address*
  • Country*
  • Information transmitted by your device when you visit our websites, use our services or receive services*
  • Information about your:
    • Device ID, device type, browser type, duration of visit and geographic location;
    • Electronic address (IP and MAC address), terminal equipment and connection information, referral URL, preferences; and
    • Information about your use of CPH’s websites and services. Such information is also collected via cookies and beacons, etc. You can read CPH’s cookie policy here.

3.2 Purpose

The purpose of collecting data in connection with CPH Hotspot is to improve CPH’s website and target the promotion of offers to you and to prepare anonymous statistics of CPH users, including the physical movement of users around CPH.

3.3 Basis of processing

Personal data processed in connection with your use of CPH Hotspot are processed on the basis of Article 6(1)(f) of the GDPR, as processing is necessary for the purposes of the following legitimate interests pursued by CPH: Ensuring that only private individuals (and not e.g. tenants) use the network, ensuring that the network is not used to download illegal material or is otherwise used in contravention of Danish law. For more information about this, read CPH’s WiFi terms and conditions here.

3.4 Recipients

In a few cases, relevant personal data are disclosed to suppliers with whom we collaborate, including suppliers of technical support and operation of our services, media agencies, advertising networks and  social media for marketing purposes.

3.5 Erasure

Data collected in connection with your use of CPH Hotspot will be anonymised on an ongoing basis.

The data are erased within 12 months of collection. 

4. WEBSHOP - CPH.DK/SHOP

 

When you order goods from CPH.dk/shop, CPH and the current operator of the TAX FREE shop, with whom you are concluding the agreement, process information about you and your purchase. The general terms and conditions applicable to purchasing products at CPH.dk/shop are available here.

4.1 The personal data collected and processed in connection with the purchase process are the following:

  • Name*
  • Address*
  • E-mail address*
  • Telephone no.*
  • Information about payment method, including credit card information*
  • Information about purchase or reservation*

4.2 Purpose

The purpose of processing personal data is to complete the purchase or ordering of goods at CPH.dk/shop.

4.3 Basis of processing

The data processed in connection with the ordering or purchase of goods at CPH.dk/shop are processed on the basis of Article 6(1)(b) of the GDPR, as the data are necessary to conclude the agreement with you on the purchase or reservation of your goods.

4.4 Recipients

CPH discloses relevant personal data to the current operator of the TAX FREE shop and other business partners to the extent necessary to complete your purchase or reservation.

4.5 Erasure

Personal data are stored by CPH for up to five years plus the current financial year in accordance with the rules of the Danish Bookkeeping Act. 

5. SECURITY, BAGGAGE AND CCTV MONITORING

 

Security is important to CPH, and in order to meet the security requirements imposed on CPH, CPH processes various data about you when you use and move around CPH.

5.1 The personal data processed in the various functions at CPH are the following:

  • Scanning of boarding cards in connection with security checks*
  • CCTV monitoring of the airport areas*
  • Screening and sorting of baggage*

5.2 Purpose

The data are processed for the purposes of complying with the requirements of Security, validating passengers through boarding cards and passports, statistics on the users of CPH, including the passengers’ movement around CPH, and generating incidence reports and handling of special transports. In order to comply with these obligations, CPH uses CCTV monitoring within CPH’s area. Moreover, CPH processes data in connection with screening and sorting of baggage.

5.3 Basis of processing

CPH is subject to a wide number of legal requirements concerning the arrangement of security measures at CPH. Accordingly, CPH’s basis of processing is Article 6(1)(c) of the GDPR, as the processing of personal data is necessary to comply with CPH’s legal obligations, including the Danish Air Navigation Act.

5.4 Recipients

In special circumstances, CPH may share relevant data with the Danish authorities, as required. In exceptional circumstances, data may be disclosed to private third parties, such as insurance companies, in connection with the settlement of disputes. In such situations, we only disclose data about the specific individual concerned. Moreover, to the extent necessary, CPH discloses data to airlines for settlement purposes in connection with CPH Fast Track and CPH Express.

5.5 Erasure

Data from boarding card validation are erased after three months.

CCTV footage filmed within CPH’s area is subject to the requirements under the Danish Data Protection Act regarding storage of such footage. Footage is erased within 30 days. In special circumstances and relating to specific cases, such data may be stored for a longer period.

Data processed in connection with the handling and sorting of baggage are erased after 5 days.

5.6 Restriction of your rights

In relation to CCTV footage within CPH’s area, your rights following GDPR Chapter III are restricted, by Article 23(1)(c) and (d) of the GDPR. Therefore you do not have the right to access the CCTV footage, due to public security reasons and the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security.

6. CPH APP

 

In connection with your downloading and using our CPH App, CPH collects various data about you, your device and your use of our app. Furthermore, cookies are registered when using the app, which you can read about in CPH’s cookie policy, which can be found here.

6.1 The personal data collected in the app are the following:

  • Information sent from your telephone/terminal equipment when you visit CPH or our websites;
    • Including information about your device ID, device type, browser type, duration of visit, geographic location, electronic address (e.g. IP and MAC address), terminal equipment and connection information, referral URL
  • Preferences and information about your use of CPH’s websites and services
  • If you are an CPH Advantage member: Name, gender, language, telephone no., e-mail address and information about your CPH Advantage membership
  • Name, address, e-mail address and payment information in connection with purchases through the app*

6.2 Purpose

We use the personal data collected to:

  1. handle orders of parking, meals and goods in CPH Webshop;
  2. improve our knowledge of you, for example to enable us to send you more relevant marketing material; and to
  3. send you targeted marketing via e-mail, push messages or other technologies. The data may also be used to produce statistics on CPH users.

6.3 Basis of processing

The data processed in connection with your order are processed on the basis of the GDPR Article 6(1)(b) (necessary for the performance of a contract with you) and Article 6(1)(f) (necessary for the following legitimate interests: marketing purposes, producing statistics).

6.4 Recipients

In certain circumstances, we share relevant information collected in the app with our business partners for the purpose of processing your order of services, including goods from CPH Webshop.

6.5 Erasure

Data collected in connection with your purchase of parking or goods in CPH Webshop are erased after five years plus the current financial year in accordance with the rules of the Danish Bookkeeping Act.

7. CONTACTING CPH

 

As a user of CPH you are, of course, welcome to contact CPH with inquiries, complaints or other matters.

7.1 Personal data processed may be the following:

  • Name, address, e-mail address and telephone no.*
  • Any information you provide that is necessary for CPH to handle your inquiry

7.2 Purpose

The purpose of processing data is for CPH to be able to help you and handle your inquiry.

7.3 Basis of processing

The data are processed on the basis of Article 6(1)(f) of the GDPR (the balancing of interests provision). The legitimate interests pursued by CPH are to assist you by answering your inquiry. In the balancing of your interests against those of CPH, it is also taken into account that CPH only processes the information that you have submitted to CPH. CPH does not obtain any additional information.

In case of complaints or claims for damages, which may contain sensitive information including e.g. health information, data are processed in accordance with Article 9(2)(f) of the GDPR (for the establishment or defence of legal claims).

7.4 Recipients

To the extent that CPH is required to do so, relevant data may be disclosed to public authorities, in particular the Transport, Construction and Housing Authority and the Police. Further CPH may, if relevant, disclose information to external advisers, including lawyers.

7.5 Erasure

Data processed by CPH when answering inquiries are erased within 24 months of the case being closed by CPH.

8. COMPETITIONS AND NEWSLETTERS

 

As a user of CPH you can subscribe to our newsletters and participate in our competitions.

8.1 Personal data processed may be the following:

  • Name, address, e-mail address and telephone no.*
  • Any information you provide that is necessary for CPH to administrate competitions or send newsletters

8.2 Purpose

The purpose of processing data is for CPH to send newsletters and administrate competitions.

8.3 Basis of processing

Data are solely used subject to your consent in accordance with Article 6(1)(a) of the GDPR. Naturally you have the right to withdraw your consent at any time.

8.4 Recipients

Relevant information can, when necessary in connection with competitions, be disclosed to business partners such as shops, restaurants, airlines etc.

8.5 Erasure

Information processed in connection with newsletters will be processed until you may unsubscribe.

Information processed in connection with competitions, are processed until the winner(s) is/are found and will be deleted hereafter, unless special conditions for the specific competition apply.

9. OTHER PROCESSING

 

9.1 Waiting time measurements

To optimise the passenger flow through the airport, CPH regularly monitors the number of passengers. In connection with this, CPH does not collect personal data – only anonymised data. CPH thus only monitors the number of people flowing through the airport to ensure that we have sufficient staff in place and lines open in e.g. the passport control or Security, as well as for statistical and analytical purposes. CPH furthermore uses this information to assess the estimated waiting times announced in the terminals and in the CPH App.

9.2 Other operators at the airport

The airport houses a wide number of independent operators, including airlines, ground handling companies, shops and other service providers. CPH is not responsible for processing of personal data by these independent operators. For example, CPH is not in charge of check-in and boarding at Copenhagen Airport, Kastrup.