Privacy Policy

The Sunclass Airlines Group understands and respects the importance of your privacy.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, in respect of your relationship with us as a customer or a potential customer.  

This information may be collected via our websites (“Sites”), our call centres, our retail stores, our mobile applications (“Apps”), or our social media channels  (collectively our “Services”). Please read the following information carefully.

By making a purchase or otherwise submitting your personal data to us, we will transfer, store or process it as set out below. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.  If you do not agree to these Terms of use, please do not use the Site or download any materials from it.

Who does this policy apply to:

This Policy applies to personal data processed by Sunclass Airlines A/S in the following web-sites: 

What types of personal data do we collect about you and why do we collect it: 

We will collect certain personal data about you and about any other person, you include on your booking.  The sort of personal data we collect will be information that you provide to us, that we collect from you or observe about you, or that we obtain from other sources.  

Personal data you provide to us

  • When you check in online, we will ask you for your name, booking number. We need to collect this information in order to register your check in on the flight. 
  • If you complete the “next of kin entry form” we will ask for your flight number, flight date, booking number and passenger name. Besides this information, we will ask for names, phone numbers and email address of your relatives. We collect this information, so we will be able to contact your relatives in case of any emergency. 
  • When you call our customer center, we record the conversation and save it for up to 200 days. We do this to know what has been said between us. We can also use the conversation in internal training and development work. We thereby collect and store all the personal information that occurs during the interview. You have the right to request that your conversation not be recorded. You also have the right to request that the recording be deleted.

To help us keep your information current, accurate and complete, please ensure you tell us if anything needs to be changed.

Personal data we collect and/or observe about you 

Based on how you have used our Services in the past and your activity on our website, social media channels, or with our contact centre and stores, we collect the following personal data about you:

  • Details of the services we have provided to you in the past, including your previous travel arrangements, such as holidays and other purchases, and matters related to those arrangements, such as details of your previous requirements or complaints. 
  • We collect details of your visits to our Sites and Apps (including, but not limited to, traffic data, location data and weblogs) whether this is required for our own purposes or otherwise, and of the resources that you access. We may use third party technology services, such as Google Analytics to administer these services.
  • We collect details of website(s) you visited before you use a link to our Sites, pages visited in our Sites, and time spent on each page. 
  • We may collect information about your computer (or mobile device/tablet) including, where available, your IP address, operating system, device location, browser type, cookie identification numbers, for system administration purposes, (both our own, and third party advertisers for whom we provide advertising services) and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and any reports we share do not identify any individuals.

Personal data obtained from other sources 

We might also receive your personal data from third party sources who collect information about you on our behalf.  This includes:

  • If you book a Sunclass Airlines holiday through a third party travel agent, certain personal data (as applicable to your booking, such as your name, date of birth or any special requirements you have) will be passed to us to provide the services you have requested/booked.

  • If you complete any of our customer feedback questionnaires/surveys, the information you provide will be processed on our behalf and provided to us by a third party.

Where is your data stored and who it’s shared with:

Your personal data is held on a combination of our own systems and systems of the suppliers we use to provide our services. 

When you provide your personal data to us, some of the personal data you provide will need to be passed to and processed and stored by relevant third parties, such as our technology partners to administer the services we provide, and airlines, airports, hoteliers, insurance companies and ground handling agents, so that they can provide you with the arrangements and assistance you require.  

Some of these third parties may be based outside of the European Economic Area (“EEA”). Organisations that are based outside of the EEA may not be subject to the same level of controls in regard to data protection as exist within the UK and the EEA.   We aim only to transfer your data to third parties outside of the EEA where either:

(a) your personal information will be subject to one or more appropriate safeguards set out in the law. These might be the use of standard contractual clauses in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme); or,

(b) the transfer is necessary to enable your contract to be performed.

In order for you to travel overseas, we may be required to disclose certain of your personal data to government bodies or other authorities , such as those responsible for immigration, border control, security and anti-terrorism.  Even if it is not mandatory for us to provide information to such authorities, we may exercise our discretion to assist them where appropriate in the interests of detecting and preventing criminal activity.

We may disclose your personal information to any member of our Group for business purposes, (those business purposes include holding your data on central/shared systems for administering bookings and supporting customers in destination countries). Our Group  means our subsidiaries, our ultimate holding company and its subsidiaries.

We may pass your data to relevant third parties for the purpose of detecting and preventing fraudulent payments or bookings.

How do we use your information when providing our services to you:

In order to provide our services to you, we use the information we hold in a number of different ways.  We process your information either because it is necessary for us to do so as part of a contract you enter into, or because we have a legitimate business reasons for doing so.  

 The following activities are carried out by us using your personal data because it is necessary in relation to a contract which you have entered into or because you have asked for something to be done so you can enter into a contract;

  • Administering your flight booking or purchase internally and communicating your flight booking 
  • To communicate with you regarding your flight booking or purchase, including sending confirmation and relevant documents;

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so:

  • To improve customer experience:
    • To allow you to participate in interactive features of our Sites and Apps, when you choose to do so.
    • To ensure that content from our Sites, Apps and booking systems is presented in the most effective manner for you and for your computer;
    • To notify you about changes to our service; 
  • To protect our business against financial loss;
    • For debt collection or credit vetting;
    • For payment card and booking verification (including using systems such as Google reCAPTCHA on some of our Sites to ensure only genuine customer bookings are made).
    • For preventing and detecting fraudulent or criminal activity; 
  • To promote our and business, improve our products and services;
    • To contact you if you make an enquiry with us on our website but do not complete a booking to check if there was a problem or you need any assistance to book;
    • For internal research/analysis to improve the quality of our Services, the products we offer and new products we are developing by:
      • Inviting customers to take part in surveys or customer/business discussion groups;
      • Using aggregated customer data to make informed decisions based on analysis of customer booking/purchase trends and behaviours. 
  • To support any potential company sale or acquisition:
    • In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

We may use and process your personal information as set out below where we consider that it is in your vital interests that we do:

  • To assist you or arrange for assistance to be provided to you by third parties either in the event of an incident or emergency.

We may use and process your personal information as set out below where we have your consent to do so:

  • To assist you or arrange for assistance to be provided to you by third parties where you have special requirements in relation to medical, health or diet;

We may use and process your personal information as set out below where there is a legal requirement for us to do so:

  • For resolving complaints, dealing with disputes and legal proceedings. This might include contacting you proactively if we need to resolve any issues you may be experiencing or have experienced with a booking/purchase;

Your rights in relation to any personal data we hold about you:

You have a number of rights in relation to your personal information under data protection law. To find out more:

Your Right to Access Your Personal Information

You have the right to make a Data Subject Access Request in many circumstances.  That is a request for access to the personal information that we hold about you.  If we agree that we have to provide personal information to you (or someone else on your behalf), we’ll provide it to you or them free of charge.

We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.  That may include information about your previous booking(s) or other purchases.  We will ask you to provide this before providing a copy of any of your personal information we may be holding to you or another person on your behalf. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. 

Please see the section titled ‘How to Contact Us’ if you need to make a Data Subject Access Request.

Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting our customer service team. You may find the contact details in the bottom.

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How do we use your information when providing our services to you’, you may withdraw your consent at any time.  If you would like to withdraw your consent to us processing any information concerning dietary requirements, medical conditions, disabilities and special requirements, please contact our customer service. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested.  If we have to cancel your booking/purchase as a result, you may incur a cancellation charge.

If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

Objecting to our use of your personal information and automated decisions made about you

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), you may object to us using your personal information for these purposes by emailing or writing to us at the address provided at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.  We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. 

Transferring your personal information in a structured data file

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in section titled ‘How do we use your information when providing our services to you’, you may ask us to provide you with a copy of that information in a structured data file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

How to contact us:

Any subject access request can be made in writing to:

Legal Dept.,
Sunclass Airlines A/S
Hangar 276
2791 Dragoer

Alternatively you can make a subject access request by email to: 

Once you have made your request and provided us with the information we need to begin a search for the data we hold on you (including proof of identity), we will have 30 days to respond.

Making a complaint

If you wish to contact us about this Privacy Policy, you can e-mail or write to the Sunclass Airlines Legal & Compliance using the contact details above.

Keeping hold of your personal data:

Where you’ve made a booking or other purchase with us, your personal information will be retained to ensure we provide the best possible customer service to you.  We also retain your personal data for legal and audit purposes.

 What is our approach to data security:

We take data security very seriously.

The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites, therefore any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep your personal data secure and to try to prevent any unauthorised access to it.  All information you provide to us is stored on our secure servers.  Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping that password confidential.  We ask you not to share a password with anyone.

What happens when you follow a link from our website to a third party website:

Our Sites include links to other websites which include privacy policies of their own. 

Our Sites contains links to and frames of websites of our principals, suppliers, advertisers and other third parties. You can tell when a third party is involved in supplying a product or service you have requested because their name will appear with ours. If you follow a link or otherwise use any of these other websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for these third party websites. Please check these policies before you submit any personal data to these websites.

We reserve the right to update this policy on regular basis.

MAY 2018


What are cookies?

A cookie is a file that is saved onto the hard drive of your computer, your smartphone or other IT devices. It makes it possible to collect data concerning your visit to a given website, any actions you perform there and can also allow that website to recognize your IP address (among other things) should you visit it again. Cookies include data that can be used by the website to optimize communication between you and your browser. In order to create the best possible overview of user behavior, we use cookies to collect information about your visit. The aim is to optimize the website and its functionality, including making it more user-friendly.

We also use data for statistical purposes in order to be able to make improvements of detailed information about how the website is used and perceived. The data that we collect is only analyzed statistically and entirely anonymously.

Sunclass Airlines places great importance on privacy protection, which is why data is collected anonymously and cannot be used to identify users. We can only see your personal data when you check in online, complete next of kin form or contact us.

When you log into Airshoppen, a cookie is stored on your computer which allows us to optimize your experience of the website. This includes saving you having to log in each time you visit a new page in our website.

If we collect your personal data, we do so exclusively to be able to respond to your questions or provide you with better service by having a better insight into your needs and interests, including delivering personalised website content and answers to specific questions.

How to remove cookies

You can always prevent cookies being saved on your computer by changing your browser settings. Most browsers are set to accept cookies automatically. You can stop cookies being stored on your computer, or block them entirely, by adjusting your browser settings. Some browsers have a setting which, when selected, deletes cookies automatically once you leave a website. This function is called InPrivate in Internet Explorer version 8 or later; Incognito in Google Chrome version 10 and later; Private Browsing in Firefox version 3.5 and later; Private Browsing in Safari version 2 and later and Private Browsing in Opera version 10.5 and later.

A detailed guide on how this function works can be found under ‘Help’ in your browser window. You can delete cookies stored on your computer at any time.

Please note that if you opt to delete or block cookies through your browser's settings, you will not be able to shop online in Airshoppen. You will, however, always have the option to make purchases over the phone.

Changes to this declaration

This declaration was last updated in October 2019.


If you have any questions about this personal data policy, please contact us by e-mail or write to:

Customer service
Sunclass Airlines A/S
Copenhagen Airport South
Hangar 276
DK-2791 Dragør, Denmark