Privacy policy / CPH Airbot

Latest update: 05 January 2024

In this Privacy Policy we describe how Copenhagen Airports A/S (CPH) processes your personal data in connection with utilizing CPH Airbot. 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. 

You can read our general privacy policy here

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 via privacy@cph.dk 

 

Use of Airbot 

CPH processes your personal data as part of your use of the CPH Airbot.  

 

Personal data processed

Upon utilizing CPH Airbot for creating an animation, we process certain data points pertaining to your face. The types of information processed include: 

  • Camera stream of your face 
  • Facial triangulation 
  • Evaluation of facial expressions and characteristics, including the coloration of hair, skin, beard, and eyebrows 
  • Graphical rendering of your face in a 3D model (the animation) 

 

Purpose 

Our objective is to provide an entertaining animation of you, offering a memorable keepsake from your visit to Copenhagen Airport. 

 

Basis for processing 

Your personal data is processed in accordance with Article 6.1.f of the General Data Protection Regulation, as the processing is necessary for CPH's legitimate interest in creating a fun and engaging initiative for our passengers in the airport. 

 

Recipients 

Your animation is temporarily stored on a server hosted by Amazon Web Services. We can also provide our IT supplier, Autonomous Units, with access to the animation to facilitate better support services. 

For clarification, the foundational facial triangulation and the analysis of facial expressions and features, integral to the animation creation, are solely processed within the CPH Airbot. This data is not shared externally and is promptly deleted post-animation creation. 

 

Deletion

Video streams capturing passengers faces are not preserved, resulting in their immediate deletion. This also applies to the facial triangulation and the analysis of facial expressions and features used in animation creation. Should you opt to create a facial animation, this representation is maintained for 10 minutes before its deletion. 

No personal data is stored beyond this 10-minute timeframe. 

 

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.  

Additionally, 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. 

If you are not satisfied with the way we process your personal data, you have the right to file a complaint with the Danish Data Protection Agency.  

 

Transfer to third countries 

The information we collect will preferably and whenever possible be processed and stored within the European Economic Area ("EEA"). However, in certain situations, information is processed in third countries outside the EEA as part of AWS’ services and support.  

For transfers to third countries, which are considered unsafe, we have taken adequate measures, for example by ensuring that the recipient is bound by EU model clauses, in order to protect personal data, or covered by the EU-US Data Privacy Framework, regarding transfers to USA. You can obtain a copy of these precautions by contacting our DPO, cf. section above. 

Further, we have ensure that no personal data that can be used directly to identify you is ever transferred outside the CPH Airbot. 

 

Privacy policy updates 

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