Privacy Policy
All information described in this Privacy Policy is processed by Delta Air Lines, Inc. ("Delta", "we", "us", or "our") as data controller. This Privacy Policy describes our practices related to the use, storage, and disclosure of personal information we collect from or about you when you interact with us in the course of our providing commercial air travel services, ancillary services, or other services provided by us or by others acting on our behalf, including when you use our website Delta.com ("Website") or our Fly Delta App ("App"). This Privacy Policy also describes our processing of personal information relating to our business partners. We will post any changes to this document. This Privacy Policy is not a contract and does not create any contractual rights or obligations.
Data Protection Officer
Delta Air Lines, Inc.
1030 Delta Blvd. Dept. 981
Atlanta, GA 30354 USA
Visit Delta’s Privacy Request Form to view the options you have to manage your personal information and submit privacy requests.
If you are a SkyMiles member, visit SkyMiles Help, opens in a new window to delete your account and make certain updates. You may also update profile information and set marketing and other preferences directly in your profile.
Your options to manage personal information may include legal rights that apply in certain contexts, such as rights related to accessing, updating, and erasing personal information, objecting to Delta’s use of personal information, reviewing automated decisions, and nominating representatives to manage your personal information.
Although we take care to directly resolve any privacy concerns, please be reminded that you may also seek redress, including by filing a complaint with the privacy authority in your country.
2.1. Direct Collection
We may collect information from you, including when you:
- use or access our Website or App, such as when you enter information during the course of a booking, even if you do not complete the booking
- register, create, or modify an online or in-app account with us, including your SkyMiles Partners, opens in a new window account and promotional partners account, or any account to use our online corporate travel tool(s), communicate with us by email, telephone, in writing, through our customer services pages, or social media
- Our SkyMiles Partners, opens in a new window are hotel, car rental, shopping, dining, vacation, and other businesses with whom you can earn, transfer, or redeem miles in the SkyMiles Program or otherwise qualify for discounts or benefits in connection with SkyMiles membership or Medallion Status. Our promotional partners are businesses with whom you may be offered a discount or benefit as a result of your transactions with Delta
- use any of our services, including when you travel with us, use airports where we operate, or use any facilities, such as Delta Sky Clubs, within those airports
- are associated with a company we do business with
2.2. Tracking Technologies
Delta and third parties access and store data on your devices to provide the Website and App, enable enhanced functionality like surveys, analyze how these services are performing to resolve issues and optimize your experience, and deliver personalized advertising. In addition to any tracking preferences available on Delta.com in your location, device and browser settings often include options to manage tracking technologies.
2.3. Other Sources
We may receive information about you from other sources, including our providers, other airlines, companies involved in booking your travel like agencies or your employer, SkyMiles Partners, opens in a new window, and promotional partners.
2.4. Purposes of Processing
This section describes what personal information we collect about you, the purposes for which we use it, and the legal basis under applicable law pursuant to which we process it. We may also use your personal information for other purposes that are reasonably expected or incidental to those described in this Privacy Policy.
The manner in which we process information depends on the type of information and purpose for processing and may include collection, organization, storage, alteration, retrieval, consultation, disclosure, restriction, erasure, or destruction.
Information related to a flight booking or purchase of our products or services, whether provided on line, over the phone, in person, at an airport kiosk or self-service device, in flight, or otherwise, and whether bought privately or through your employer or company including:
- your name and title;
- your national ID, in certain circumstances;
- your contact details, such as postal address, telephone numbers, and email address;
- your flight, luggage, boarding and other ticketing information, such as bag tag tracking number and luggage screening information, including X-ray images of checked luggage;
- special assistance requests and preferences;
- your billing and transaction information such as credit/debit card type and number(s), corporate forms of payment, and related data including associated billing address, and expiration date(s);
- emergency contact(s);
- seating preferences, medical needs, and dietary requests;
- flight, car, and hotel preferences;
- travel companions’ personal information;
- information about who is meeting or dropping you off;
- your order for other services, such as cargo, animal services, and inflight services such as upgrades, beverages/food, and goods;
- any employer or company information associated with your booking;
- your reason for travel.
We use this information to:
- provide you with your flight and other products and services;
- provide assistance with bookings and seat assignments including where relevant for our corporate travel program customers, in cooperation with their corporate travel managers;
- confirm your travel arrangements and remind you about incomplete bookings;
- take your payment and make any refunds or credits and send any confirmations;
- send you service communications, such as notifications of flight schedule changes, and check-in opening;
- manage and administer our services and business, including performing our record-keeping requirements;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
- confirm your identity and to prevent fraud;
- improve our products and services, including through statistical analysis and research for program development;
- send you marketing communications, offers, and invitations to events, which may be based on our segmentation and modelling of your personal information;
- provide you with assistance in an emergency, including communicating with your emergency contacts;
- share it with other airlines for the purposes of your itinerary or re-booking you if there is a travel disruption;
- share it with our SkyMiles Partners, opens in a new window and promotional partners for the purpose of their providing services to you;
- share it with authorized government agencies and as otherwise described in this Privacy Poilicy;
- share it for luggage security screening to enable you to travel within and between countries;
- tailor our products and services for you, including anticipating your likely preferences based on information concerning your previous travel with us, previous transactions, or communications with us, any of which we may combine with other information we have about you, and which may be based on our segmentation and modelling of your personal information.
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent, for example, to us using information related to your health and dietary requirements, certain credit card information, or information to send you marketing communications;
- it is necessary to protect your or a third party’s vital interests or to respond to a public health incident;
- it is necessary to act in the public interest;
- it is necessary to comply with applicable law and regulations, such as those related to flight operations, identity verification, and emergencies;
- the information is publicly available;
- we have a legitimate business interest, for example, in assisting you with making and managing your bookings with us, managing and administering our business and protecting it from fraud, improving and promoting our service and better understanding how customers use it, ensuring that our technical systems operate properly, protecting against risks to customers and aircraft, streamlining customs clearance processes for our customers, enabling Delta to support public health efforts, ensuring the health and safety of customers traveling on Delta flights, and complying with applicable law and regulations;
- we and third party airlines have a legitimate business interest in making and operating connections between multiple flights and expediting baggage clearance across international borders; or
- we and our SkyMiles Partners, opens in a new window, promotional partners and other businesses that are providing services that you request have a legitimate business interest in using the information to provide their services.
Customer identification information, including:
- Secure Flight Passenger Data, such as your government issued ID; your full name; your contact details, such as postal address (or temporary address in the U.S. for non-U.S. customers); telephone numbers; email address; date of birth, gender; Known Traveler Number; and Redress Number;
- Advance Passenger Information such as passport or other travel document number (including machine-readable information), nationality, issue date and location, expiry date, and country of residence;
- information from the Department of Homeland Security or similar authorities responsible for security in other countries, if traveling from certain airports;
- biometric information (such as finger, face, voice, or iris).
We use this information to:
- verify and authenticate your identity;
- undertake security screening to enable you to travel within and between countries, as required by most governments;
- comply with legal and regulatory requirements;
- confirm your identity at check-in, bag check location, security checkpoints, and when boarding the aircraft;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
- share it with governments and as otherwise described in this Privacy Policy;
- provide you with your flight and other products and services;
- send you service communications, such as expired or expiring passport.
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent, for example, to us using information related to your passport (beyond what is necessary for us to provide your flight), biometric information, or information to send you marketing communications;
- it is necessary to protect your or a third party’s vital interests, or to respond to a public health incident;
- it is necessary to act in the public interest, such as protecting against risks to customer and public health, customer and aircraft safety, and unlawful cross-border activities;
- it is necessary to comply with applicable law and regulations, such as those related to flight operations, identity verification, and emergencies;
- the information is publicly available; or
- we have a legitimate business interest, for example, in protecting the security of your SkyMiles account and your travel reservations, ensuring that our technical systems operate properly, enabling Delta to support public health efforts, ensuring the health and safety of customers traveling on Delta flights, and complying with applicable law and regulations.
Information related to your membership in our Delta Sky Club, the SkyMiles Program or other account, or activities with our SkyMiles Partners, opens in a new window and promotional partners, including:
- your name and contact details;
- your SkyMiles status;
- your SkyMiles account number;
- your transactions and SkyMiles Program activity;
- your choice of SkyMiles benefits;
- your flight information including any travel group to which you are assigned;
- your membership information for SkyMiles Partners, opens in a new window or other account and promotional partners loyalty programs;
- your employer or company details, your role, use of corporate forms of payment, and other information submitted through our online corporate travel tool(s), where you agree to associate your SkyMiles Program account with your employer’s or corporate business SkyBonus/SkyMiles for Business or other travel program
- your date of birth;
- your gender;
- your user ID, password and log-in credentials when using our online corporate travel tool(s) and access your accounts with us;
- your digital image, if you consent to its collection in connection with access to our lounges.
We use this information to:
- provide you with services related to your SkyMiles Program membership and activity with SkyMiles Partners, opens in a new window, or promotional partners, if applicable, including mileage tracking;
- tailor our products and services for you, including anticipating your likely preferences based on information concerning your previous travel with us, previous transactions, or communications with us, any of which we may combine with other information we have about you, and which may be based on our segmentation and modelling of your personal information;
- improve our products and services, including through statistical analysis, segmentation, and research for program development;
- manage and administer our Delta Sky Clubs or the SkyMiles Program and for our related record-keeping requirements;
- associate · your SkyMiles Program account with your employer’s or corporate business SkyBonus/SkyMiles for Business or other travel program to enable you to earn SkyMiles on your business travel, enable your employer or company to earn any business bonuses; enable your employer or company to administer and allocate your expenses, ticket, and other travel payments and procure travel assistance; and to otherwise operate that business account;
- send you information about our products and services;
- send you marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;
- recognize your loyalty to the SkyMiles Program;
- share your information with SkyMiles Partners, opens in a new window and promotional partners as mentioned in this Privacy Policy;
- verify and authenticate your identity to prevent fraud ; and
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical).
We use this information because:
- it is necessary to enter into or to perform a contract with you relating to SkyMiles Program membership;
- you have given consent, for example, to us using information to personalize your in-flight experience, using your digital image to grant you lounge access, or using information to send you marketing communications;
- it is necessary to comply with applicable law and regulations;
- the information is publicly available; or
- we have a legitimate business interest, for example, in improving our service, personalizing it for our customers, and better understanding how customers use it, managing and administering our business and protecting it from fraud, ensuring that our technical systems operate properly, promoting and developing our business, and complying with applicable law and regulations.
Information related to your preferences and personal and professional interests, and your opinions of our services, including:
- information about your Internet activity;
- your survey responses;
- your responses to our marketing efforts;
- your demographics;
- your contact preferences;
- your experience with our products and services.
We use this information to:
- provide our products and services to you;
- tailor our products and services for you based on this information alone and in combination with other information we have about you;
- improve our products and services, including through statistical analysis and research for program development;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical):
- send you marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;
- send you online messages about products and services provided by us or our SkyMiles Partners, opens in a new window, promotional partners, and other third parties that may be of interest to you.
We use this information because:
- it is necessary to enter into or to perform a contract with you;
- you have given consent, for example, to us using information to send you marketing communications;
- the information is publicly available; or
- we have a legitimate business interest, for example, in enabling you to manage your preferences and account details, improving our service, personalizing it for our customers, and better understanding how customers use it, ensuring that our technical systems operate properly, and promoting and developing our business.
Information from your use of our Website or App, including corporate travel online tool(s) accessed through them, including:
- your Internet service provider;
- your browser type;
- your operating system;
- pages you access on our Website or App;
- the date and time of your access to our Website or App;
- your device type;
- the IP address or unique identifier of your device;
- your location, established from GPS or network based features;
- feedback you provide to us;
- your log-in credentials, if you have a SkyMiles or other account with us;
- your online transactions with us;
- your role or registration when using our corporate travel online tool(s).
We use this information to:
- operate and administer our Website and App;
- provide our products and services to you. In the case of services provided through the App, these will be only the services you have chosen within the App;
- improve our products and services, including through statistical analysis and research for program development;
- send you messages and offers, about products and services provided by us or our SkyMiles Partners, opens in a new window, promotional partners and other third parties that may be of interest to you, which may be based on your online behavior combined with other information we have about you and/or segmentation and modelling of your personal information;
- tailor products and services for you, based or your browsing history on our Website, and use of the App, and combining this information with other information we have about you;
- identify issues with our Website and App and users' experience of them;
- monitor the way our Website and App are used;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
- support your use of location-based tools, such as airport directions and map views, city code search, displaying local Delta Sky Clubs, and locating parking spaces;
- send you information about services in your location which may be of interest;
- administer your online account, if you have one;
- recognize your role when administering our corporate travel program to generate appropriate training, support and promotional content within the tool or by email.
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent, for example, to us using information to send you marketing communications;
- it is necessary to protect your or a third party’s vital interests, or to respond to a public health incident;
- it is necessary to act in the public interest;
- it is necessary to comply with applicable law and regulations;
- the information is publicly available; or
- we have a legitimate business interest, for example, in understanding how our Website and App are accessed, how they are used, any security issues affecting their operation, and any problems users have with the Website or App across multiple devices, improving our service and better understanding how customers use it, providing you with information relevant to your travel with us, ensuring that our technical systems operate properly, promoting our products and services and those of third parties, and in personalizing the information that our Website or App sends to you about these things, and complying with applicable law and regulations.
Information from your communications with us and our staff, including:
- interactions in person on board our flights, or with ground staff;
- emails, letters, online "chats", surveys, and telephone calls with our staff including our customer service teams;
- via social media.
We use this information to:
- deal with any issues and concerns;
- provide our products and services to you;
- personalize our services;
- manage and administer our services and business and for our record-keeping requirements;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
- improve our products and services, including through research for program development;
- send you marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;
- monitor communications for staff training, and quality checking purposes.
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent, such as in the case of information used to send you marketing communications;
- it is necessary to protect your or a third party’s vital interests, or to respond to a public health incident;
- it is necessary to act in the public interest;
- it is necessary to comply with applicable law and regulations, such as those related to flight operations, identity verification, and emergencies;
- the information is publicly available; or
- we have a legitimate business interest, for example, in managing and administering our business and our relationship with you, ensuring that our technical systems operate properly, improving and developing our products and services, promoting and developing our business, and complying with applicable law and regulations.
Information relating to travel and aircraft emergencies, including:
- your involvement in medical incidents affecting you and others during your travel with us;
- professional information about individuals involved in your care;
- your designated emergency contact.
We use this information to:
- assist you and your family members if there is an emergency;
- provide you with your program benefits;
- provide you with appropriate and timely communications;
- comply with legal and regulatory requirements;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical).
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent;
- it is necessary to protect your or a third party’s vital interests, or to respond to a public health incident;
- it is necessary to act in the public interest;
- it is necessary to comply with applicable law and regulations, such as those related to flight operations, identity verification, and emergencies;
- the information is publicly available; or
- we have a legitimate business interest, for example, in ensuring that our technical systems operate properly, complying with applicable legal and regulatory requirements, and complying with applicable law and regulations.
Information we receive about you from other sources, including:
- from SkyMiles Partners, opens in a new window or other account, promotional partners, your SkyMiles Program activity and redemptions;
- from other airlines, your and your fellow travelers' Passenger Name Record containing your names and itineraries;
- from travel agencies;
- from your employer;
- demographic information from public records and third parties;
- from financial institutions and credit checking agencies.
We use this information to:
- administer your SkyMiles Program membership and rewards;
- administer your Delta Sky Club membership;
- provide you with flights;
- manage and administer our services and business and for our record-keeping requirements;
- combine it with other information for statistical research and marketing purposes;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
- develop and promote our products and services;
- check for and receive payment approval.
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent, for example, to us using information to send you marketing communications;
- it is necessary to protect your or a third party’s vital interests, or to respond to a public health incident;
- it is necessary to act in the public interest;
- it is necessary to comply with applicable law and regulations, such as those related to flight operations, identity verification, and emergencies;
- the information is publicly available; or
- we have a legitimate business interest, for example, in improving and developing our products and services, performing our contract with your employer, ensuring the health and safety of customers traveling on Delta flights, ensuring that our technical systems operate properly, and complying with applicable law and regulations.
Business information of travelers on corporate accounts and of representatives of suppliers, customers, and other businesses (including for cargo) we deal with, including:
- name, role and personal contact details at the company and personal information in communications with you;
- corporate contact, and employer or affiliation (e.g., employer name, title, contact details, and contract information);
- user ID, password and log-in credentials when using our corporate travel online tool(s).
We use this information to:
- conduct our business dealings with our suppliers, customers, partners, and other businesses including for sales and purchases, and enabling use of our corporate travel online tool(s);
- tailor our products and services for you based on this information alone and in combination with other information we have about you;
- administer your company’s SkyBonus/SkyMiles for Business and other corporate travel benefits;
- send you or your company marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;
- recognize your role when administering our corporate traveler program to generate appropriate training, support and promotional content within the tool or by email;
- maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical).
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent, for example, to us using information to send you marketing communications;
- the information is publicly available; or
- we have a legitimate business interest, for example, in performing our contracts with our corporate customers, suppliers and other business, developing our business with our corporate customers, and ensuring that our technical systems operate properly.
Information required by public health authorities or other government agencies or collected to demonstrate fitness to fly, including:
- contact information, such as name, nationality, country of residence, originating address, destination address, telephone, and email;
- information collected by our ground or reservations staff pursuant to directives by public health organizations or other government agencies.
We use this information to:
- comply with legal and regulatory requirements;
- determine your fitness to travel consistent with applicable government regulations and guidelines.
We use this information because:
- it is necessary to enter into or to perform a contract with you to provide flights or other products or services;
- you have given consent;
- it is necessary to protect your or a third party’s vital interests, or to respond to a public health incident;
- it is necessary to act in the public interest;
- it is necessary to comply with applicable law and regulations, such as those related to public health;
- the information is publicly available; or
- we have a legitimate business interest, for example, in ensuring the health and safety of customers traveling on Delta flights, and complying with applicable law and regulations.
We only base our processing of personal information on our legitimate interests when we consider that our legitimate interest is not overridden by the individual's interests or rights.
As used in this Privacy Policy, “consent” means any statement or clear affirmative action by which you agree to the processing of personal information for a specific purpose. Please note that where you have provided your consent to us for processing your information, you can withdraw this at any time.
2.5. Information collected through our App
Delta may collect and receive personal information from the App users through the Software Development Tools (SDKs) deployed on the Fly Delta App. Depending on the SDK, the type of personal information collected and received via the SDKs may include, without limitation, the App user’s name, email address, phone number, mailing address, SkyMiles number, credit card information (to the extent a credit card transaction is being made through the App), customer flight information, App usage metrics, and device information such as IP address. Delta may use such information to verify and authorize credit card transactions, to receive feedback about the App and services, and to track and analyze usage of the App.
We use push notification tokens in the App to send notifications to your mobile device with updates for flight times, gate changes, and flight cancellations. The App will activate your camera if you choose to take a picture for a parking reminder, and will store the photo for you to look at later. If you choose, the App can access your device calendar to save itinerary information in your personal schedule. It can also bring up your default e-mail program, so you can send notes and reminders while traveling.
At times, we may promote the App via internet advertising on external websites. If you click on these advertisements and navigate directly to a third party application or other platform, information such as your phone’s device identification number may be sent to the advertising network, so that they and we may track the effectiveness of our advertising. This information might also be used for capping the number of times a specific visitor to a website is shown a particular advertisement, estimating the number of unique users, debugging, or security and fraud detection.
2.6. Legal requirements and professional advice
We may also use your personal information where this is necessary to comply with a reasonable request by a law enforcement or regulatory authority, body, or agency, or to defend legal claims.
We may also use your personal information when obtaining legal and other professional advice including for audits. We consider this to be in our legitimate interest in the management of our business.
2.7. What if you do not provide information?
In some cases, we are legally required to collect certain information from you so we can provide the services you have requested, such as Secure Flight Passenger Data or Advance Passenger Information when you make a reservation to fly within, into, or out of the United States, or for point-to-point international travel. Failure to provide this information will mean we cannot provide the service.
In some circumstances we need your information to perform our contract with you or to provide products and services, such as payment details and, on occasion, credit checking information. If you do not provide this information, we may not be able to enter into or perform the contract or provide the products and services.
2.8. Authorization on behalf of another customer
When you provide information to us about your travel companions or other individuals (if, for example, you have arranged to make a booking on their behalf), you confirm to us that you have obtained their authorization to provide us their information and their consent to your use of their information in accordance with this Privacy Policy. If you cannot make these confirmations, you must not provide us with any personal information about these individuals.
2.9. Sensitive Information
We may process sensitive or special categories of personal information, such as that relating to health, disabilities, race, ethnicity, political opinions, biometrics, or religion, for the purpose(s) for which it was provided or for which you have provided express consent. For example, we may collect and receive sensitive personal information from you when you:
- provide such information to us, a travel agent, or another third party involved in your travel arrangements at the time of or following your booking;
- disclose to us that you have a specific medical condition, will have an accompanying service animal, or request specific medical care or assistance, such as the provision of an accompanying nurse or wheelchair assistance, from us, an airport, or a third party involved in your travel arrangements;
- make a request that implies or suggests something about you which could be interpreted as sensitive personal information, such as a request for a specific type of meal that may suggest that you have a certain medical condition or hold a particular religious belief;
- consent to the collection of your digital image to enable our supplier's facial recognition system for lounge access purposes; or
- provide information required by public health authorities or other government agencies
We occasionally receive personal information from law enforcement agencies and other sources relating to criminal activity (or alleged criminal activity) and may use that information where necessary, and where permitted by applicable law, to detect or prevent unlawful activity occurring during air travel. We consider this to be in the substantial public interest.
Some services may require the disclosure of sensitive information to third parties. We will notify you of any right to deny consent in advance of processing sensitive information, where required by law.
3.1. In general
We may share personal information with:
- you or those authorized to act on your behalf
- customers traveling under the same booking as you
- third parties that provide services to Delta, such as our customer care center operators and providers of technical services such as data centers, biometric verification services, and online tools
- third parties that provide you with services you request, such as travel segments on other carriers, hotel accommodations, rental cars, SkyMiles Partners, opens in a new window, promotional partners, and other Delta Group Companies for the purposes described in and in accordance with this notice. Further information regarding Delta Group Companies is available in Delta’s public U.S. Securities and Exchange Commission filings
- other airlines, including members of the SkyTeam Alliance, to service your travel, recognize your loyalty program status, rebook your flight in the event of an unexpected disruption in your travel, or protect crewmembers, customers, and the overall safety and security of our flight operations and those of our alliance partners
- your employer, expenses administration providers, corporate travel assistance providers, travel agencies, corporate travel managers, and/or duty of care providers if your SkyMiles Program account is associated with your employer’s or corporate business account, or when you use your employer’s corporate account, SkyMiles for Business number or a corporate form of payment to book your travel
- banks, financial firms and payment services to process payments and refunds
- third parties with whom we are discussing selling any part of our business or to whom we sell any part of our business
- government agencies and authorities, law enforcement officials, law courts, or to third parties: (a) if we believe disclosure is required by applicable law, regulation or legal process (such as pursuant to a subpoena or judicial order); (b) to protect and defend our rights, or the rights, health, or safety of third parties, including to establish, make, or defend against legal claims; or (c) in the interest of public health and safety.
3.2. Social Media and Messaging Platforms
You may wish to share information regarding your travel or other activities with Delta on social media and messaging platforms provided by third parties. To utilize social media and message sharing features, you will be prompted to grant permissions within those third-party platforms, as you choose. For example, you will need to allow account login and publishing permissions. If you choose to contact or interact with us on a third-party social media or messaging platform, you understand that you are responsible for reviewing and understanding the terms and conditions, information security practices, and privacy policy applicable to the third-party platform, and that Delta is not responsible for how third-party social media and messaging platforms use, share, or protect your information. The activity on third-party social media and messaging platforms, and the data processed, stored, and provided on them, including data regarding interactions with Delta, is governed by the terms and conditions, information security practices, and privacy policy of those third-party platforms.
3.3. SMS/Text
Delta will not disclose personal information collected through text messages to third parties for their own marketing purposes.
3.4. Group and multi-passenger bookings
When you make a booking, you will be provided with a booking reference such as a confirmation number or record locator number. Your booking reference should be kept confidential at all times. Disclosing your booking reference to other customers may allow them to access your booking details through our systems. If you are traveling with others under the same booking and would not like your individual booking details to be disclosed to them, you may prefer to have each person make and pay for separate bookings.
3.5. Optional biometrics services
You may choose to use facial comparison technology for identity verification, including at flight check-in, bag drop, and boarding gates. If you choose to use facial comparison technology, your image is taken when you would otherwise present another form of identification. The image is encrypted and sent to U.S. Customs and Border Protection (CBP) for the purpose of verifying your identity. If CBP determines that the image matches images associated with your passport or images in CBP's database, CBP transmits a unique identifier back to Delta through an encrypted channel. Delta may associate the unique identifier with other information about you, such as your name and flight number, for the purpose of providing the relevant service. Delta does not receive any biometric information.
For more information about CBP’s facial comparison technology, see the CBP Traveler Verification Service Privacy Impact Assessment. Please note that if you choose to use facial comparison technology at TSA check points or during CBP processing, TSA and CBP control the processing of your personal information.
3.6. Unaccompanied Minors
Delta shares information related to unaccompanied minors, such as itinerary information, to protect the safety of the child traveling on Delta flights, coordinate transportation and other services, and comply with legal and regulatory requirements.
We store your information as necessary for the processing activities described in this notice and to comply with Delta’s record retention policies and legal and regulatory requirements. For information about specific retention periods, please submit your question through Delta’s Privacy Request Form.
Delta and its partners and providers process personal information in the United States and globally and implement technical, organizational, and contractual measures designed to protect this information. Delta implements additional contractual safeguards called standard contractual clauses (“SCC”) to govern the transfer of personal information to certain countries that may not have the same level of protection as the country of export. For a copy of these SCC, please submit your question through Delta’s Privacy Request Form.
Delta is a member of the SkyTeam Alliance, a global network of airlines that process personal information to provide passengers with a more seamless travel experience. For more information, please read the SkyTeam Alliance Joint Privacy Notice.
SkyMiles IP Ltd. and SkyMiles IP Finance Ltd., located at c/o Maples Corporate Services Limited, P.O. Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands, is the controller of SkyMiles information.
Delta has appointed its branch at Metro Building 1, Butterwick, London as its UK representative and its branch at Vertrekpassage 1 – 110, 1118 AP Schiphol, The Netherlands as its European Union representative.
Delta has appointed the following branches as its representatives in China:
Room 2105 and 2106, Yueyang Plaza, 1601 Nanjing West Road, Jing'an District, Shanghai
Room 1008, Beijing Kerry Centre South Tower,No.1 Guanghua Road, Chaoyang District, Beijing, PR China
This section describes our specific practices related to the use, storage, and disclosure of your personal information in Peru and supplements the generally applicable sections of this Privacy Policy. It applies to personal information we collect from or about you when you interact with us in the course of our providing commercial air travel services, ancillary services, or other services provided by us or by others acting on our behalf in Peru, including when you use our Website or our App. With respect to personal data collected or processed by Delta’s branch office in Peru, the provisions discussed here take precedence over any inconsistent or deviating provisions set out in the generally applicable sections of this Privacy Policy.
1. Updates
Delta reserves the right to modify this Privacy Policy and will post any changes in an updated version of this policy.
2. How to Contact Us?
For the exercise of data protection rights and/or if you have any questions or comments regarding this Privacy Policy, please contact our Data Protection Officer using Delta’s Privacy Request Form.
3. How Delta Uses Your Data
This section describes what personal information we collect about you, the purposes for which we use it, and why we use it. Your personal data will be collected and processed in accordance with Law N° 29733 - Law of Protection of Personal Data, and applicable regulations, approved by D.S. 003-2013-JUS. Your personal data will be incorporated into the Personal Data Database named "Pasajeros", "Skymiles Usuarios Web" and "Procedimientos, quejas y reclamos” identified with RNPDP code No. 17069, 17065 and 17063 (Databases). Any processing of personal data that we perform is in accordance with the provisions of the privacy laws in Peru, and this data may only be used for the limited purposes discussed in this section.
The data controller in Peru is Delta’s Branch office in Peru, DELTA AIR LINES INC. SUCURSAL DEL PERÚ (en adelante, “Delta”), con Registro Único de Contribuyente No. 20387428331, located at Av. Elmer Faucett 2851, Edificio Lima Cargo City, Oficina 406, Callao, Lima, Peru.
Information related to the provision of our services, including:
- your first and last name;
- your national ID number;
- your postal address, telephone numbers, and email address;
- your Skymiles number;
- your billing and transaction information such as credit/debit card type and number(s), related data including associated bank details and billing address, and expiration date(s);
- your date of birth;
- your gender;
- your nationality;
- your emergency contact information; and
- information related to your physical and mental health.
We use this information to:
- manage the requested service;
- facilitate the provision of complementary services when you have ordered them or consented to them;
- contact you if necessary and/or use your information for any service(s) related to the ticket sale;
- your protection in case of delays or cancellation of the service;
- provide you with the benefits of the SkyMiles program and the attention to complaints.
We use this information for the reasons, and subject to the limitations, specified below:
- it is necessary to enter into and perform our contract with you to provide flights or other products or services;
- we have a legitimate business interest in assisting you with making and managing your bookings with us;
- we have a legitimate business interest in managing and administering our business and protecting it from fraud;
- in the case of information relating to your health, and dietary requirements, if you have consented to our using it to meet special assistance requests and preferences at the point of collection;
- in the case of our storage of information related to your credit card (beyond what is necessary to process your payment), if you have provided your consent at the point of collection;
- we have a legitimate business interest in improving and promoting our service and better understanding how customers use it;
- we do not use your personal information to send you marketing communications unless you have provided your consent at the time of collection, which communications may include marketing communications related to our SkyMiles Program, promotions, communications related to additional services and advertisements;
- we do not use your personal data to send you marketing communications when you provide us with your personal data through the Comments/Complaints form on delta.com;
- we have a legitimate business interest in ensuring that our technical systems operate properly;
- we must comply with certain regulatory requirements regarding emergencies and otherwise in relation to operating passenger flights. We also have a legitimate business interest in complying with legal and regulatory requirements applicable in Peru;
- we and third party airlines have a legitimate business interest in making and operating connections between multiple flights and expediting baggage clearance across international borders;
- we and our SkyMiles Partners, opens in a new window, promotional partners and other businesses that are providing services that you request have a legitimate business interest in using the information to provide their services;
- we have a legitimate business interest in protecting against risks to customers and aircraft;
- we have a legitimate business interest in streamlining customs clearance processes for our customers.
4. What if You Do Not Provide Information?
In some cases, we are legally required to collect certain information from you so we can provide the services you have requested, such as Secure Flight Passenger Data or Advance Passenger Information when you make a reservation to fly within, into, or out of the United States, or for point-to-point international travel. Failure to provide this information will mean we cannot provide the service.
In some circumstances we need your information to perform our contract with you or to provide products and services, such as payment details. If you do not provide this information, we may not be able to enter into or perform the contract or provide the products and services.
Any processing of personal data that we perform is in accordance with the provisions of the current data protection legislation of Peru, and this data may only be used for limited purposes such as those mentioned in this section.
5. Sensitive Information
We may collect or receive sensitive or special categories of personal information, such as that relating to health, disabilities, race, ethnicity, political opinions, biometrics, or religion, where permitted by applicable law. For example, we may collect and receive sensitive personal information from you when you:
- provide such information to us, a travel agent, or another third party involved in your travel arrangements at the time of or following your booking;
- disclose to us that you have a specific medical condition, will have an accompanying service animal, or request specific medical care or assistance, such as the provision of an accompanying nurse or wheelchair assistance, from us, an airport, or a third party involved in your travel arrangements; or
- make a request that implies or suggests something about you which could be interpreted as sensitive personal information, such as a request for a specific type of meal that may suggest that you have a certain medical condition or hold a particular religious belief.
We will collect, store, use, and transfer your sensitive personal information for the purposes for which it was provided and otherwise in accordance with the terms of this Privacy Policy if you provide your express consent at the time of collection.
6. Data Retention
We store your information for as long as legally required and for so long as necessary to support business purposes described in the generally applicable section 3 of this Privacy Policy and consistent with our record retention policies.
7. With Whom Does Delta Share Your Information?
We may disclose your personal information we collect or receive:
- to third parties to process your information on our behalf, or to assist us in providing our services and/or products, such as our customer care center operators and providers of technical services such as data centers and online tools; however, Delta requires that third parties comply with Delta’s Privacy Policy when processing your information;
- to the party providing the service or product when you request or purchase services or products through Delta that are to be provided by another party (for example, Iron Mountain Peru S.A., CORPAC S.A., catering, VIP lounges, such as SUMAQ and HANAQ), hotels, transport companies, accounted outsourcing, Lima Airport Partners S.R.L., Talma Servicios Aeroportuarios S.A., and security companies;
- to other Delta Group Companies, including Delta Air Lines, Inc., a Delaware corporation with registration number 2387598 domiciled in the United States of America, for the purposes described in and in accordance with this Privacy Policy. Information regarding the Delta Group Companies is available in the generally applicable section 7.1 of this Privacy Policy and Delta’s filings with the Securities and Exchange Commissions, including SEC Form 10-K.
- to government agencies and authorities, law enforcement officials, law courts, or to third parties: (a) if we believe disclosure is required by applicable law, regulation or legal process (such as pursuant to a subpoena or judicial order); or (b) to protect and defend our rights, or the rights or safety of third parties, including to establish, make, or defend against legal claims.
8. Your Rights
This section applies only to the personal information of individuals in Peru which grants the rights described here.
- Right to access your personal information
To the extent you are legally entitled, you can request confirmation of whether or not we process your personal information, and details of the information that we hold about you and how we use it.
You also have a right to access your personal information and to be provided with a copy.
- Right to rectification of personal data
If you believe that the personal data we hold about you is inaccurate, you may request that we correct it. You may also request us to complete personal data about you which is incomplete. We will make reasonable efforts to revise any information that is incorrect, or update or change your information as we are required to do by applicable law.
- Right to restrict the processing of personal data
You have the right to request that we restrict processing of your personal information where one of the following applies:
- You claim that the personal data is not accurate. The restriction will apply until we have taken steps to ensure the accuracy of the personal data.
- The processing is unlawful, but you do not want us to erase the personal data.
- We no longer require the personal data for the purposes of processing, but you still need it in connection with a legal claim.
- You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.
- Right to request deletion of personal data
You may request the erasure of your personal information in certain circumstances. For example, you may request erasure if:
- The personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
- You have withdrawn your consent and we have no other legal basis for processing the personal information.
- You have exercised your right to object to processing the personal information, and we have no overriding legitimate grounds to continue processing it.
Under certain circumstances, we may refuse a request for erasure, for example, where we need to use the personal data to comply with a legal obligation or to establish, make or defend legal claims.
If you exercise your right to erasure, this will potentially remove records which we hold for your benefit, such as your SkyMiles account information (including miles that may be in your SkyMiles account) and your presence on a marketing suppression list.
- Right to object to processing of personal data for specific purposes
You have a right, at any stage, to object to our using your personal information to send you marketing information.
You also have the right to object to our using your personal information where our reason is based on our legitimate interests. We will have to stop processing until we can establish that we have compelling legitimate grounds which override your interests, rights, and freedoms, or that we need to continue using it for the establishment, exercise, or defense of legal claims.
- Right to withdraw your consent
Where you have provided your consent to us for processing your information, you can withdraw this at any time by opting out in your SkyMiles Profile, or by contacting us through Delta’s Privacy Request Form.
9. Exercising These Rights
In order to exercise the rights described in this section, you must submit a request in accordance with the provisions of the Regulation of Law No. 29733. Any request you make must be in writing and include your name and address and any other information that may identify you, such as where your request relates to a travel booking, please provide your booking reference (e.g., confirmation number or record locator number), SkyMiles Account number if you have one, the dates on which the travel took place, and any other relevant information that will assist us to identify your booking. You must also provide a photocopy of your passport or driver’s license so we can verify your identity. Please send your written requests to our Data Protection Officer through Delta’s Privacy Request Form.
10. Security
Information Security is important to Delta. We have established appropriate physical, electronic, and managerial safeguards to protect the information we collect in accordance with this Privacy Policy and to protect against unauthorized access, disclosure, loss, misuse, alteration, and improper use of your information, and to maintain the accuracy and integrity of that data.
11. Complaints to Regulator
You have a right to file a complaint with the National Authority of Personal Data Protection by addressing the front desk of the Ministry of Justice and Human Rights (Calle Scipión Llona 350, Miraflores, Lima Peru) in connection with your rights under this Privacy Policy.