1. Operator of the Tool
The operator of the tool responsible for data processing is:
Lufthansa Industry Solutions AS GmbH
Sudportal 7
D-22848 Norderstedt, Germany
2. Purpose of Processing
This tool allows you to submit an innovation idea and receive AI-generated feedback.
Your data is processed for the following purposes:
- Generating AI-based feedback on your submitted idea
- Contacting you regarding your idea submission
- Providing information about the Mydea innovation management platform
- Responding to inquiries and initiating potential follow-up communication
3. Data Processed
We process the following data:
Idea-related data
- Idea title
- Idea description
Personal data
- Name
- Company name
- Email address
4. Use of Artificial Intelligence (Azure OpenAI)
To provide feedback, your idea title and description are processed using an AI service (Microsoft Azure OpenAI).
- Only the idea content is used for generating feedback
- Your contact details (name, company, email) are not used for AI processing
- The idea content is processed temporarily and not stored on our servers
5. Data Storage
- Idea content: not stored after AI processing
- Contact data: stored only for follow-up communication related to your inquiry and Mydea
According to LHIND's general retention policy:
- Contact data from inquiries may typically be stored for up to 12 months
- Data may be retained longer where legal retention obligations apply
6. Legal Basis
Data processing is carried out in accordance with the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
Processing is based on:
- Art. 6(1)(b) GDPR - to provide the requested service (AI feedback)
- Art. 6(1)(a) GDPR - consent to process contact data for follow-up communication regarding your idea submission and information about Mydea
7. Recipients of Data
Your data may be processed by:
- Internal departments responsible for innovation services and Mydea
- Technical service providers supporting the operation of this tool
LHIND generally engages service providers, for example for communication and IT infrastructure, in accordance with applicable legal requirements.
8. Data Processing & International Transfers
Where external service providers are used:
- Processing is carried out under Data Processing Agreements (Art. 28 GDPR)
- If data is transferred outside the EU/EEA, appropriate safeguards (e.g. Standard Contractual Clauses) are applied
9. Your Rights
You have the right to:
- Access your data (Art. 15 GDPR)
- Rectify inaccurate data (Art. 16 GDPR)
- Request deletion (Art. 17 GDPR)
- Restrict processing (Art. 18 GDPR)
- Data portability (Art. 20 GDPR)
- Object to processing (Art. 21 GDPR)
You also have the right to lodge a complaint with a supervisory authority.
10. Contact for Data Protection
For any data protection inquiries, please contact:
- Data Protection Officer (Lufthansa Group)
Email: datenschutz@dlh.de - Data access requests
Email: dataaccess@lhind.dlh.de - Data privacy related topics and withdrawal of consent
Email: marketing.sales@lhind.dlh.de
11. Withdrawal of Consent
Where processing is based on consent, you may withdraw your consent at any time with effect for the future.
To withdraw your consent or request its removal, you may contact us at marketing.sales@lhind.dlh.de.
The withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
In accordance with Art. 17 GDPR, you may also request the erasure of your personal data where you have given consent and subsequently withdraw it, provided that no other legal basis for the processing exists. The right to erasure may also apply to processing that is based on legitimate interests under Art. 6(1)(f) GDPR if you object to such processing pursuant to Art. 21 GDPR and there are no overriding legitimate grounds for continuing the processing.
This is without prejudice to statutory retention obligations or other circumstances in which processing remains necessary under applicable law, including for the establishment, exercise or defence of legal claims.
Further Data Protection Information
Additional information is available in the full Lufthansa Industry Solutions privacy notice: https://www.lufthansa-industry-solutions.com/de-de/datenschutz