(Last updated: 12 July 2023 – v1.9)
The purpose of this full Privacy Notice (“Privacy Notice”) is to describe the personal data processing we perform in connection with your use of the Wizz Air Chatbot (“Amelia”) on Meta’s Messenger platform. If you wish to know more about the data processing activities of Wizz Air entities, please consult our Privacy Notice you may find on our website www.wizzair.com. If you wish to know more about Meta’s data processing activities, please see Meta’s Privacy Policy.
Please note that this Privacy Notice applies only if you are using our Chatbot on Meta’s Messenger platform. In case you are using our Chatbot on the www.wizzair.com website or in the Wizz Air application, please consult the applicable Privacy Notice.
Joint Data controllers and their arrangement
The joint controllers of your personal data are:
- WIZZ Air Hungary Ltd. (seat: Laurus Offices, Kőér street 2/A, Building B, H-1103, Budapest, Hungary), Wizz Air UK Limited (Main Terminal Building, London Luton Airport, Luton, United Kingdom, LU2 9LY), Wizz Air Abu Dhabi LLC (Wizz Air Abu Dhabi, PO Box 145076 Abu Dhabi, UAE) and Wizz Air Malta Limited (171 Old Bakery Street, Valletta 1455 VLT, Malta) (hereinafter jointly referred to as “Wizz Air”); and
- Meta Platforms Ireland Limited (seat: 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland; hereinafter referred to as “Meta”; Wizz Air and Meta hereinafter jointly referred to as “we”, “our” or “us”).
Wizz Air entities have signed a joint controller arrangement, which sets out the related roles and responsibilities. Wizz Air Hungary Ltd (and the Wizz Air Group DPO) is responsible for replying to your privacy related questions, queries or complaints, however, you may exercise your data protection rights in respect of and against each of the Wizz Air entities as joint data controllers. Wizz Air Hungary Ltd is also responsible for providing you with information in relation to this processing (as set out in this Privacy Notice) and notifying the relevant supervisory authority in the event of a data breach. If you would like to know more regarding the joint controller arrangement, please contact us at data.protection@wizzair.com.
The Chatbot is integrated with Meta’s Messenger platform using Mindsay’s platform. Wizz Air and Meta have entered into a joint controller arrangement relative to the processing of your data when you interact with the Chatbot. For more information on the joint controller agreement between Meta and Wizz Air please see the Meta Controller Addendum.
What is the Purpose of Processing the Data?
Wizz Air will use your data for the purposes below:
- Responding to your queries and requests: the purpose of processing your personal data is to respond to your queries and requests to us; for this purpose, Wizz Air relies on our legitimate interest.
The provision of your personal data is voluntary. However, if you do not provide your data, you may not be able to use our services i.e., you will not be able to use the Chatbot.
Meta will process your data for the purposes outlined in their Privacy Policy.
What Personal Data We Process about you?
For the purpose outlined above Wizz Air will process the data categories indicated below:
- Meta’s Messenger Data: the Chatbot is integrated with the Meta’s Messenger platform, therefore Wizz Air may process public information you may have already provided to Meta such as your name, gender, or information that Wizz Air may receive from Meta such as your Facebook user ID, message ID, your language.
- Customer Care data: including name, address, date of birth, e-mail address, telephone number, Wizz account number, government ID, flight history, content of your request, communication with you, payment and credit card data.
You may find information about the personal data Meta processes about you in Meta’s Privacy Policy
The legal bases for processing your personal data
To process your personal data, Wizz Air will rely on the legal bases below:
- The processing of your personal data is possible based on legitimate interest under Article 6 (1) f) GDPR (“Legitimate Interest”).
Wizz Air has a legitimate interest in processing data to respond to your questions, inquiries because it is critical to engage with Users if they have queries to maintain their confidence in Wizz Air. If Users have contacted Wizz Air with a question (or complaint), it is reasonable for them to expect that their data will be processed to facilitate a response.
Wizz Air may process your personal data for the purposes and legal bases indicated below:
Purpose of data processing | Categories of personal data processed | Legal Basis | Retention period |
Responding to your queries and requests | - Meta’s Messenger Data
- Conversation Data
| Legitimate Interest | Wizz Air may store your personal data collected while interacting with the Chatbot up to one year. Meta may store your personal data collected during your interaction with the Chatbot in accordance with Meta’s Privacy Policy. |
You may find information on the legal bases and purposes for which Meta processes your personal data in Meta’s Privacy Policy.
Who may access to your data?
Within Wizz Air, employees with appropriate authorization may have access to your personal data on a “need-to-know” basis. Wizz Air may engage other persons, third parties as data processors to provide services and courts, government bodies or other authorities may require Wizz Air to disclose your data them.
- Service providers: Wizz Air uses externally provided IT-systems or services provided by third party vendors as a support to internal processes.
Data processors | Seat | Activity |
Laiye | 131, avenue Parmentier, 75011 Paris, France | Chatbot development and operation. |
Amazon Web Services | 38 Avenue John F. Kennedy, L- 1855 Luxemburg | Cloud services and data storage |
DeepL | DeepL GmbH Maarweg 165 50825 Köln, Germany | Translation Services |
Google Ireland Ltd. | Google Building, Gordon House, Barrow Street, Dublin 4, Ireland | Translation Services |
salesforce.com EMEA Limited | Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, United Kingdom | CRM and LiveChat functions |
- Wizz Air Group: your personal data may be shared within the Wizz Air Group if needed. For more information about Wizz Air Group, please visit https://wizzair.com/en-gb/information-and-services/about-us/company-information.
- Government authorities and enforcement bodies: Wizz Air may share your personal data with government authorities or enforcement bodies such as regulatory authorities, upon their request and only as required by the applicable law or to protect our rights or the safety of Wizz Air customers, staff and assets.
Personal data may be provided to parties that are located outside the European Economic Area ("EEA"). In such cases, Wizz Air will ensure that your personal data is transferred in line with applicable requirements set out by Chapter V of the GDPR.
When using the Chatbot, Wizz Air may transfer your personal data to the United Kingdom, outside the EEA. The United Kingdom is acknowledged and under the EU Commission Implementing Regulation no. 2021/1772 on the adequate protection of personal data by the United Kingdom to provide an equivalent level of protection as provided by European Union law.
In case Wizz Air transfers your personal data outside the EEA to a country not acknowledged to provide an equivalent level of protection, Wizz Air shall ensure that recipients located outside the EEA will provide an adequate level of data protection for the personal data and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. For this purpose, Wizz Air signed the Standard Contractual Clauses under the EU Commission’s implementing decision no. 2021/914 with such recipients.
Meta may share your personal data with other third parties in accordance with Meta’s Privacy Policy.
Your rights
If we process your personal data based on your consent, then you can freely withdraw your consent any time. The withdrawal of your consent does not affect the lawfulness of prior processing.
You are entitled to exercise your rights indicated below:
- Right of access: You have a right to ask whether or not we process personal data about you and, if that is the case, request information about the personal data we process.
We may request additional information from you for identification or for further copies requested by you, or we may charge a reasonable fee based on administrative costs.
(ii) Right to rectification: We are required to rectify inaccurate personal data, or to complete personal data that is incomplete, on your request.
(iii) Right to erasure (right to be forgotten): We are in some circumstances required to erase personal data on your request.
(iv) Right to restriction of processing: We are in some circumstances required to restrict our use of personal data on your request. In such cases, we may only use the data for certain limited purposes set out by the law.
(v) Right to data portability: You may have the right to receive your personal data to which we have access, in a structured, commonly used and machine-readable format and may then have a right to transmit those data to another entity without hindrance from us.
(vi) Right to object:
If you consider that your privacy and data protection rights have been infringed by Wizz Air, you may contact the competent data protection authority located in the European Union’s relevant Member State where your habitual residence, place of work or place of the alleged infringement is or the Hungarian National Data Protection and Freedom of Information Agency (Nemzeti Adatvédelmi és Információszabadság Hatóság – NAIH; address: H-1055 Budapest, Falk Miksa u. 9-11.; website: www.naih.hu; phone: +36-1-391-1400; email address: ugyfelszolgalat@naih.hu; fax: +36 1 391 1410.
If you are a UK resident, you may lodge a complaint with the Information Commissioner’s Office (address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone: 0303 123 1113; fax: 01625 524510; live chat: https://ico.org.uk/global/contact-us/live-chat/live-chat-individuals/).
You may also exercise your rights directly against Meta regarding Meta’s data processing activities
You have the right to object to the processing of your personal data for any reason relating to your situation, and in this case, Wizz Air may not be able to process your personal information. If you have the right to object and the exercise of this right is justified, your personal data in concern will not be further processed for the purposes of the objection. The exercise of this right does not entail any costs.
Contact the data protection officers
If you have any further questions about the Privacy Notice or how Wizz Air processes your personal data please contact us by sending your query to us to the email address data.protection@wizzair.com or via letter to the Wizz Air Group Data Protection Officer at Wizz Air Hungary Ltd., Laurus Offices, Kőér street 2/A, Building B, II-V., H-1103 Budapest.
If you have any further questions concerning how Meta processes your data, you may either:
- Contact Meta online;
- Contact Meta’s Data Protection Officer online; or
- Write a letter to Meta Platforms Ireland Limited, 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland.
