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Data Protection Statement for Recording Telephone Calls to the Customer Center

English Version
Data Controller is:
BERlogic GmbH
Lankwitzer Str. 39, 12107 Berlin
(hereinafter referred to as BERlogic)

HRB 142271 B in Amtsgericht Berlin Charlottenburg
USt-ID: DE283001723

Tel: +49 30 983 20 88 0
Fax: +49 30 983 20 88 99
Mail: infoweb@berlogic.de

Legal Representative (Managing Director):
Mr. Igor Tsodykovskiy
You can contact our Data Protection Officer:
Mr. Jürgen Becker
E-mail: datenschutz@berlogic.de
Purpose of the processing and what are the legal grounds for processing your personal data?
We process personal data in accordance with the provisions of the GENERAL DATA PROTECTION REGULATION (GDPR) and the Federal Data Protection Act (BDSG) for the following purposes and on the following legal bases:

When you call to the customer center of BERlogic GmbH, we record and store the telephone conversations so that we can provide a service requested by you (e.g.: purchase and cancellation of the flight ticket, booking of additional luggage, provide you information, in particular about changes to flight data or time, etc.) and to carry out billing. In addition, we protect the passenger against unauthorized changes in the booking and we can prove that the customer has requested and used a certain service.

The recording of telephone conversations is necessary for the purposes of the legitimate interests of BERlogic GmbH (Art. 6 para. 1f GDPR), that we can prove the performance of a contract to which the data subject is party. Nevertheless, telephone calls to the customer center will only be recorded with your consent (Art. 6 para. 1a DS-GMO). The consent is, when you press a button "1" on the phone keypad.
What phone data do we store?
When making calls, we store the telephone number, date, time and duration of the call, as well as the content of the call: first and last name, booking number, service requested. The storage period is 4 years, starting from the end of the calendar year in which the telephone conversation was recorded or in which a complaint/ claim is filed. After that, the corresponding data is routinely deleted. The recordings of telephone conversations are stored in Germany.
Who receive your personal data?
Our employees, service providers and partners, when processing of personal data, are obliged to preserve the confidentiality of the data secrecy and to compliance with the data protection laws. They have access to your data only to fulfil our contractual and legal obligations.

Our data processors (Art. 28 GDPR data processing agreement) can also receive data for the purposes mentioned above. Usually these are companies in the categories of service providers:

  • external customer centre: your personal data are used to provide you on request with additional services, such as cancellation of tickets, changes to flight times or the subsequent posting of additional luggage;
  • cloud IT service providers: to operate virtual server, network and data storage infrastructures.

If we authorize any data processors to provide our services, we will take appropriate legal measures and appropriate technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

Your personal data will be not transferred to a third party, which has no direct connection to your booking. We transfer the data to third party only if the processing is necessary for the performance of a contract (art. 6 paragraph 1 point b GDPR) or for the purposes of the legitimate interests (art. 6 paragraph 1 point f GDPR) in an economic and effective operation of our business or with your consent (art. 6 paragraph 1 point a GDPR).

In the case of a lawsuit, a recorded telephone conversation can be (in rare cases) transferred to a comparison portal, where you have booked the airline tickets, external lawyer, court.
Transfers of personal data to third countries or international organisations
Our servers and databases are located in Germany, our service providers and partners are located in the EU, EEA and in other countries (third countries). The transfer of the personal data occurs in accordance with data protection laws, in particular the European Data Protection Regulation (GDPR).

Please note if the recipients of your data are located in countries where the adequacy of the level of protection pursuant to art. 45 GDPR does not ensured, we conclude standard data protection clauses adopted by the Commission in accordance with the examination procedure referred to in art. 93(2) GDPR (art. 46 paragraph 2 point c GDPR) or we ensure that they are certified (such as Google) according to the EU-US-Privacy-Shield. You can obtain or view the standard data protection clauses in a copy. If necessary, please contact us via under point 1 mentioned contact details.
What are my data rights?
Every data subject has the right to:

  • Right of access in accordance with art. 15 GDPR (you have the right to request information about your personal data stored by us at any time)
  • Right to rectification in accordance with art. 16 GDPR (in the event that your personal data is incorrect or incomplete, you may request the correction of this data),
  • Right to erasure in accordance with art. 17 GDPR and Right to restriction of processing in accordance with art. 18 GDPR (you have the right to erasure or restriction of the processing of your personal data, if, for example, there is no longer a legal business purpose for such processing and legal storage obligations do not require further storage,
  • Right to data portability in accordance with art. 20 GDPR (you have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance

Furthermore a gived consent can be withdraw at any time with effects for the future.

In addition, there is a right to lodge a complaint with a supervisory authority (art. 77 GDPR in conjunction § 19 The New German Federal Data Protection Act). You can find the supervisory authority responsible for you at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Moreover, we would like to point out your right of objection in accordance with art 21 GDPR.
Information about your Right to object in accordance with art. 21 GDPR
You have the right, for reasons relating to your particular situation, at any time to object to the processing of personal data based on art. 6, paragraph 1, point e GDPR (data processing in the public interest) and art. 6 paragraph 1 point f GDPR (data processing on the basis of a balancing of interests).

In case of objection, we shall shall no longer process your personal data, unless we demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

The objection can be form-free and there are no costs other than the transmission costs according to the base tariffs.

You can at any time and free of charge get information about all your personal data we store.

In order to exercise your rights to object, please, contact us:

BERlogic GmbH
Lankwitzer Str. 39, 12107 Berlin
datenschutz@berlogic.de
Is there automated individual decision-making, including profiling?
We do not process your data automatically with the aim of evaluating certain personal aspects (Profiling).
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