Privacy policy
We take data protection and confidentiality very seriously and adhere to the provisions of the General Data Protection Regulation (GDPR) as well as current national data protection regulations. Please read this data protection information carefully before submitting a report.
Responsible party and data protection officer
The party responsible for data protection in the whistleblowing system is:
AirPlus International GmbH
Dornhofstr. 10
Neu-Isenburg, 63263, Germany
Our organisation has appointed a data protection officer. Enquiries regarding data protection can be sent to dataprotection@airplus.com.
The whistleblowing system is operated by a specialised company, EQS Group AG, Karlstraße 47, D-80333 Munich in Bavaria, Germany, on our behalf.
Personal data
Personal data and information entered into the whistleblowing system is stored in a database at a high security data centre operated by EQS Group AG. Only our organisation can see the data. EQS Group AG and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data is stored encrypted with multiple levels of password protection according to a system of permissions so that access is restricted to a very small selection of expressly authorised persons.
Purpose and legal basis of the whistleblowing system
The whistleblowing system (BKMS® System) is used to securely and confidentially receive, process and manage reports concerning compliance and legal violations. We will process your personal data if it is necessary to fulfil legal obligations. This includes, in particular, reports on criminal, competition and labour law issues (Article 6 (1) (c) GDPR).
Furthermore, your personal data will be processed if it is necessary to protect the legitimate interests of the organisation or a third party (Article 6 (1) (f) GDPR). We have a legitimate interest in the processing of personal data to prevent and discover violations within the organisation, to check the lawfulness of internal processes and to protect the integrity of the organisation.
Type of collected personal data
Use of the whistleblowing system is voluntary. We collect the following personal data and information when you submit a report using the whistleblowing system:
- your name, if you choose to reveal your identity,
- whether you are employed at our organisation, and
- the names and other personal data of persons that you list in your report, if applicable.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees in the Compliance Organisation and are always handled confidentially. The employees in the Compliance Department evaluate the matter and carry out any further investigation required by the specific case.
While processing a report or conducting a special investigation, it may be necessary to share reports with additional employees of our organisation or employees of other group companies, e.g. if the reports refer to incidents in subsidiaries. These subsidiaries may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports.
All persons who receive access to the data are obliged to maintain confidentiality.
Information about the accused party
We are legally obliged to inform accused parties of any reports received against them as soon as the disclosure of this information no longer jeopardises the investigation. Your identity as a whistleblower will not be disclosed unless we are legally bound to do so.
Rights of the data subjects
Pursuant to European data protection legislation, you and the persons named in the report have a right of access, rectification, erasure and restriction of processing, and a right to object to the processing of your personal data. If the right to object to the processing of the personal data is exercised, the necessity of the stored data for the examination of a report will be evaluated immediately. Data that is no longer needed will be erased without undue delay. You also have the right to lodge a complaint with the supervisory authority.
Retention period for personal data
Personal data is retained for as long as necessary to clarify the situation and perform a final assessment or for as long as a legitimate interest exists on the part of the organisation or retention is required by law. After the report processing is concluded, the data will be erased in accordance with statutory requirements.
Use of the whistleblowing system
Communication between your computer and the whistleblowing system takes place over an encrypted connection (SSL). The IP address of your computer will not be stored during your use of the whistleblowing system. To maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer. This cookie merely contains the session ID (a session cookie). This cookie is only valid until the end of your session and expires when you close your browser.
You can set up a secured postbox within the whistleblowing system with an individually chosen pseudonym/ user name and password. This allows you to send reports to the respectively responsible employee either by name or in an anonymous, secure way. This system only stores data inside the whistleblowing system, which makes it particularly secure. It is not a form of regular email communication.
Note on sending attachments
When submitting a report or an addition, you can also send attachments to the responsible employee. If you wish to submit an anonymous report, please take note of the following security advice: Files may contain hidden personal data that could jeopardise your anonymity. Please remove all such information before sending a file. If you are unable to remove such data or are uncertain about how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.
Version: 06/03/2024