Politique de confidentialité
This policy is designed to inform all users of Aena airport facilities and users of our corporate website.
What is the purpose of this document?
The purpose of this document is to notify you that your personal details are processed in accordance with Personal Data Protection laws, in particular, those of Regulation (EU) 679/2016 of the European Parliament and Council of 27 April 2016, relating to the protection of individuals with regards to the processing of personal data and free circulation of those data (GDPR) and Organic Law 3/2018 of 5 December on Personal Data Protection and Guarantee of Digital Rights.
Who is the Data Controller?
The data controller will be:
In the event that you enjoy services provided at the Región de Murcia International Airport, the data controller will be:
How does this Policy affect me if I am a user of the airport facilities?
We inform all users of our airport facilities of the following:
What types of data will be processed?
The following types of personal data are processed:
Keep in mind that, on occasions, for the proper provision of services and the contract execution, you will be required to provide mandatory data, for the development of the contract, or data required to comply with relevant legal obligations. Otherwise, the contract cannot not be executed or signed, or Aena could not comply with its legal obligations.
Why do we process your personal data?
The personal data that you provide to us or that will be provided at the time you start your relationship with us and those that may be collected or generated throughout that relationship, will be processed for the purposes indicated in each fact sheet, personal data collection form or by any other means that is made available to you at the airport itself, and are summarised below:
Managing and handling airport claims, as well as managing and processing all types of claims/complaints/suggestions/requests for information, basing such processing on the consent given. You can withdraw your consent at any time, by sending an email to email@example.com, indicating “Withdrawal of Consent” + Type of Request + Airport, attaching information proving your identity. The data will be kept during processing, as well as during the period in which a complaint may arise. The data shall be communicated, where appropriate, to the airline, company or body involved in processing the claim, complaint, request or suggestion; to Judges and Courts in the event that your complaint leads to legal action, as well as to the authorities established by law. No international transfers are planned.
This service includes the management, control and processing of claims, complaints and suggestions sent to both Aena S.M.E., S.A. and Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia S.M.E., S.A. or to Aena Desarrollo Internacional S.M.E., S.A., where appropriate, as well as all types of complaint, claim or suggestion services through the Online Services Portal on the Aena website.
If you are an Authority, your data will be processed to manage and control the services provided to Authorities: managing visits, managing authority lounges, recording and maintaining institutional contacts, based on compliance with a legal obligation. We also inform you of the origin of the data; sometimes they may come from the public body or administration to which you belong. The data will be kept for the duration of your relationship with our company, and for as long as a complaint may persist. No communication to third parties or international transfer of data is foreseen.
Sending comercial comunications where appropriate, based on your consent. You can withdraw your consent given at any time, by sending an email to firstname.lastname@example.org indicating “Withdrawal of Consent Commercial Communications”, attaching information proving your identity.
Managing airport users: visits, based on your consent. We will also manage your temporary accreditation for the visit (as a visitor and/or for operational or professional reasons), access control and security of the facilities; and we shall monitor visits to the airport or centre, basing this processing on a legal obligation (private security regulations) and public interest (airport security). The data will be kept during the management of the visit and for a period of one month, as well as during the period in which a complaint may arise. Your data may be communicated to the Security Forces, in accordance with legal obligations, and no further transmissions or international transfers are foreseen, other than where there is a legal obligation to do so.
Managing your request for assistance to People with Reduced Mobility (PRM).The company will also carry out a satisfaction survey in order to improve the service, basing these processing on the correct performance of the contract. To access the service, you go to the designated areas in the airport or book the service in advance through the Aena website or your airline. Your data may arrive at Aena from the airline company if you make the reservation through your company's website or travel on an arrival flight to an airport in the Aena network from other airports. Your data will be kept for as long as necessary to fulfil the purpose, as well as for as long as a complaint may arise. There is no provision for transmissions (except by law) or international transfer of data.
Processed data: Identification, contact, health data (type of disability or special needs) and flight details.
When appropriate, recording your telephone calls to certain telephones (operational, incident investigation, emergencies), based on your consent, fulfilment of contract, vital interest, public interest, exercise of claims, as appropriate (depending on the type of call made).
The period of retention of the recordings will be that necessary for the end or purpose for which they were made; however, they will be blocked only at the discretion of judges and courts for the rest of the period before their destruction. The period before the recordings are destroyed will be determined by the purpose of the recording. No international transmissions or transfers are envisaged, unless legally required.
Management and handling of complaints from the car park: We inform you that the images captured by the car park access cameras, which include cameras that capture the vehicle's data (front and/or rear licence plate recognition and reading system), will be used to comply with legal obligations including those derived from the legislation regulating the parking contract, such as the obligation to identify the vehicle. In some airports, your image as a driver, captured on entry to and exit from the car park for security purposes, may be processed, based on the public interest (see Video Surveillance). Likewise, your entry and exit details, registration number and details of your reservation, if applicable (see information regarding the processing “Aena's Parking Reservation”), will be processed for the management of the car park. This processing is based on the fulfilment of the contract. Your data may be processed for the processing and resolution of claims, in compliance with legal obligations.
In the case of parking of subscribers or staff, additionally, we will process your data (identification and contact details and, where appropriate, your company’s data), which may be provided by your company, for the management of your subscription. This processing is based on the fulfilment of a contract (and where appropriate, the contract between your company and Aena. In this case, your data may be communicated to your company for the development of this contract), which will be kept for the duration of your subscription and, subsequently, for the legal periods in the event of any complaint. Processed data: Images of the vehicle (front and/or rear licence plate recognition), entry and exit time, licence plate obtained and your reservation details if applicable, means of payment.
The images captured will be kept for the duration of the stay in the car park and will subsequently be kept for a maximum of one month. The car park management data will be kept for the duration of your stay and/or your contract (in the cases indicated above), as well as for the period that a complaint may arise.
The data may be communicated to your bank to charge the service provided (if applicable), to your company, if necessary for the performance of your contract (if applicable) and the transfer of the data is foreseen to the State Security Forces for the purpose of preventing a real danger to public safety or for the repression of criminal offences, and to Judges and Courts in the event of a court order. No international transfers are envisaged.
Likewise, in the case of subscribers to some of the car parks at our airports, we will process their data (contact details) for sending commercial communications and conducting surveys. These treatments are based on your consent given. Aena informs that the consent given can be revoked at any time by sending an email to email@example.com.
Controlling passengers passing through security checkpoints to the boarding area and, where appropriate, recording incidents in such access (in compliance with a legal obligation) and make statistics (based on legitimate interest). The processing consists of checking that the boarding pass read corresponds to a flight on the day that has not yet taken place. If everything is correct, it allows it to pass through the checkpoint. In any case, you will have the opportunity to challenge the decision taken and to request that these checks be repeated by a security operator.
Fast Lane – Fast pass checkpoint for VIP airline passengers. Legitimation: necessary for the fulfilment of the contract. The system allows the passenger to pass through the Fast Lane checkpoint if she/he has acquired this VIP right from the airline or has acquired this right on the Aena website.
Data processed: the data read from your Boarding Pass, using the boarding pass readers located before the security checkpoint and Fast Lane checkpoint step.
Management of airport medical services provided by Aena or any external collaborating entity contracted for this purpose, with the aim of providing a first aid service (emergency primary care and emergency medical transfer) at the airport, as well as to produce statistics. Your data will be processed on the basis of legitimate interest (to obtain statistics), and on the basis of compliance with legal obligations (health regulations), or to protect your vital interests in the event of inability to provide it.
Processed data: Identification and health details.
Your data will be kept for the time necessary to comply with the purpose for which they are collected and to determine any responsibilities that may arise from that purpose and their processing, taking the health regulations that apply as a reference. Your data may be communicated to hospitals or other medical centres if the service provided is deemed necessary for the same purpose. In any other case, no data will be communicated, unless legally obliged or required by a court. No international transfers are planned.
Free Aena Wifi Service: In order to offer the Wifi service, AENA may obtain personal contact details that have been provided by the USER at the time of accessing or registering for the Wifi service.
The legal basis for the processing of USER data is the fulfilment of the contract for the provision of Wifi services according to the Terms and Conditions of Use, as well as the fulfilment of legal obligations related to Article 31 bis of the Criminal Code and the obligation of Law 25/2007, on the retention of data in electronic communications.
At the same time, if the USER explicitly accepts by checking this acceptance option, Aena may use the data provided in registration to this Wifi service, as well as the data obtained from navigation and geolocation to provide a customised experience by sending commercial and advertising communications by electronic means, sent by Aena itself, such as newsletters with information of interest to passengers or promotions and discount coupons from the Aena Airport shops or from third parties on the following areas or sectors: Automotive and car rental, leisure, travel agencies, tourism, transport, airlines, catering, the textile industry, fashion, beauty and cosmetics, financial and insurance, press and magazines, gambling, betting.
This processing is based on your consent. AENA hereby informs you that consent given to this effect can be revoked at any time by sending an email to firstname.lastname@example.org or email@example.com entering “REMOVAL OF WIFI CONSENT” in the subject. In the event that the USER requests the revocation and/or cancellation of the sending of commercial and advertising communications and/or information by electronic means indicated, AENA will process the data associated with the device and the data of the USER's login credentials in order to be able to process the cancellation request. In no case does the withdrawal of consent condition the fulfilment of the contract for the provision of the Wifi service. The sending of commercial and advertising communications and/or information by electronic means indicated, the prospective offer of products and services for commercial, advertising or general information purposes, as well as statistical and segmentation purposes is based on the consent requested from the USER.
Processed data: Identification details such as email address (if access is by email), password and username (if access is by Aena Club Cliente) or other equivalent data if access is by social networks. There are also other data that are recorded in the system and are also mandatory for the purposes mentioned, such as: name of the device that connects to the Wifi, MAC address, IP address, telephone number and IMEI (if the access is via a telephone) and connection and navigation data, geolocation.
Your data will be kept for the time necessary to comply with the purpose for which they were collected, as well as the period established by legal obligation in Law 25/2007. They will also be stored for as long as claims and responsibilities may arise as a result of the processing of your data for the purpose for which they were collected.
No data will be passed on to third parties except for the obligations provided for by law. If necessary for the development of the activity or the provision of the service, the data may be transferred internationally, for which Aena will take the appropriate measures.
How does this Policy affect me if I am a user of the website?
We inform all users of our website of the following means of processing:
Regarding the Aena Employment section: There are two types of processing:
You can withdraw your consent given at any time, by sending an email to firstname.lastname@example.org indicating only “Withdrawal of Consent Interested Parties”; or “Withdrawal of Consent Selection”, attaching information proving your identity.
Aena, Aena Desarrollo Internacional and Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia will be responsible for the processing of your personal data that will be used to manage job applications and selection processes managed through the website.
The data will be kept for the duration of the selection process, as well as for the period during which a complaint may arise.
Interested parties: we inform you that once you have registered as an interested party, your email address will be saved for the three years immediately following, after which it will be deleted from our database, and you will have to register again if you are still interested in future selection processes.
Your data relating to your applications for employment, as indicated above, may be communicated to the trade union representatives if necessary in accordance with the applicable regulations. In addition, we inform you that by legal obligation of the Law 19/2013, of 9 December, on Transparency, Access to Public Information and Good Government, for participation in any of the processes, the results of candidates may be published on the web, previously dissociated from other personal data.
For certain job applications, your data may be provided to the State Security Forces for criminal records checks, based on public interest (National Civil Aviation Security Programme).
To the entities of the Aena Group that are beneficiaries of the selection processes, operating in airport management, based on your consent, in the event that you apply for a post for these entities and no further international transfers or transmissions are envisaged, except under legal obligation.
With regard to our Aena Club Cliente service, the purposes are:
Aena is promoting a biometrics project at the Adolfo Suárez Madrid-Barajas Airport. If, voluntarily, you decide to use this new service (processing based on your consent), you will be able to access it in your capacity as a member of Aena Club Cliente, notwithstanding the additional information required for the provision of the service.
Given the special nature of biometric data, Aena guarantees compliance with all the legal obligations that relate to it in terms of data protection.
More information is available at the end of this policy.
Finally, in the event of contracting a product with an associated obligation to pay, if payment is not made within the period stipulated and the requirements set out in the regulations are not met, the data relating to non-payment may be transferred to files relating to the failure to comply with monetary obligations.
In accordance with the Terms and Conditions, sending communications with information regarding these discounts, promotions, offers, news and benefits of the Aena services is a necessary requirement for subscription to the agreement between yourself as a registered member and user of the Club, and Aena, and to have access to these benefits. Therefore, by unsubscribing from these communications you will also cancel your Club membership, meaning you will not be informed of the discounts, promotions, offers, news and benefits applicable at any time to the services offered through the Club.
Consequently, if you do not wish to receive these communications with information on these benefits you may request to be removed from the communications at any time through the relevant channels.
From your account, by logging into the clubcliente.es portal and accesing "My data" to manage consents.
Through the unsubscribe link included at the bottom of the communication received.
Emailing email@example.com, with the subject "Unsubscribe Commercial Communications".
If you request a service for the Región de Murcia International Airport, your details will be sent to Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia S.M.E., S.A., a subsidiary of Aena which manages the airport, for the provision of the service.
No further communication or international transfer of data is envisaged unless legally required.
The data will be kept for as long as you remain a member of the Club, as well as for the appropriate legal periods of time to deal with any claims and responsibilities arising from the processing.
You can withdraw your consent at any time.
Club Cliente members may also use the following services (based on the fulfilment of a contract):
Payment by mobile. You are hereby informed that Aena will store the last four digits of your credit card in order to identify the card used for payment of the contracted service.
When using the Parking services, your car registration number will be stored to allow us to determine how long you have used the parking services, so that we can bill you accordingly.
If you pay for access to one of the VIP Lounges managed by Aena using your mobile device, your ID information will be collected for identification purposes.
In the event that the member associates the payment made through our mobile application with his or her status as a member of the “Club Cliente”, please note that Aena will process the information collected to create a commercial profile as a member of “Club Cliente”, to segment the customers who are members of the Club, to send personalised commercial offers, and to improve their experience as a user of our mobile application.
Payment by Registration. This new stay management and payment system for stays in the car park offered by Aena will entail processing the vehicle registration and credit card details provided by the user in his or her Aena Club Cliente profile.
The Payment by Registration service involves reading and identifying the vehicle registration number when entering and leaving the car park. It will therefore not be necessary to issue a ticket when entering and leaving. Once you have entered the car park, the reader will recognise your registered number plate, and this will be associated with the user with the Payment by Registration service enabled, which will automatically raise the barrier and allow you to enter and park your vehicle. This service is only intended for vehicles. This means that motorcycles are excluded from using the Payment by Registration system, in light of complexities arising when reading their registration numbers.
In order to enjoy club discounts, you will need to scan your return boarding pass so that the new balance can be calculated and automatically saved.
As regards the Aena Car Park Bookings, the data you have provided will be processed for the purpose of managing car parking space bookings that you make through our website. This processing is based on the fulfilment of a contract. At the same time, and with your permission, we will email you commercial and advertising correspondence, such as newsletters with information of interest to passengers, offers and discount coupons for Aena Airport shops or for third parties concerning the following areas or sectors: cars and vehicle hire, leisure, travel agencies, tourism, transport, airlines, catering, the textile industry, fashion, beauty and cosmetics, finance and insurance, press and magazines, and gambling (processing based on your consent).
The interested party has the right to withdraw consent for commercial communications at any time, without this affecting the management of the contracted service.
The data from your reservation will be processed later for the management of the car park itself (for more information, see previous section “Management and handling of complaints from the car park”).
The data will be kept for as long as you remain a customer, as well as for the legal periods of time required to deal with any claims and responsibilities arising from the processing.
Your data may be communicated to Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia S.M.E., in the event that you make a reservation through the Aena website for a car park for the airport; to your bank, in order to make the payment for the service provided, and, if applicable, to your company or carrier, if the entity is the contracting party of the service you receive; the legal basis of the processing is the fulfilment of the signed contract. Likewise, if payment is not made within the term established for it and the requirements set out in the regulations are not met, the data relating to the non-payment may be communicated to files relating to the non-fulfilment of monetary obligations.
The purpose or airport VIP Services is to manage VIP Lounge access purchases that you make via our website, as well as to send you information that may be of interest to you. The services are as follows:
Likewise, surveys will be carried out on the quality of the service provided, with processing based on legitimate interest.
The interested party has the right to withdraw consent for commercial communications at any time, without this affecting the management of the contracted service.
The data will be kept for as long as you remain a customer, as well as for the legal periods of time required to deal with any claims and responsibilities arising from the processing.
Your data may be communicated to Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia S.M.E., S.A., if you request a service for the Región de Murcia International Airport, a subsidiary company of Aena which manages the Airport, for the provision of the service; to your bank, for the payment of the service provided; if appropriate, your personal details may be communicated by Aena to the companies contracting the VIP space (your company or airline) in order to manage access to it, this processing being legally authorised by the fulfilment of the signed contract. Likewise, in the case of contracting a product that has a payment obligation associated with it, if payment is not made within the term established for it and the requirements set out in the regulations are not met, the data relating to the non-payment may be communicated to files relating to the non-fulfilment of monetary obligations. No international transfers are planned.
If, on behalf of your company, you request a service aimed at companies (for example, Suppliers’ portal), your personal data, as a representative of the company, will be processed to carry out the necessary steps to provide the services requested and offered by the Suppliers' portal (consultation and downloading of Contract Specifications, and subscription to receive alerts on new tenders from Aena).
Processing is based on your consent, and your contact details are used to establish relations with your company. Processing is based on legitimate interest, in accordance with Law 3/2018, on Personal Data Protection and Guarantee of Digital Rights. AENA informs you that the consent given to this effect can be revoked at any time by sending an email to firstname.lastname@example.org indicating “REMOVAL OF PROVIDERS CONSENT” in the subject and attaching your identification information. Your data will be kept for as long as you do not ask for it to be removed, as well as for the period that a complaint may arise. There is no provision for transmissions (except by law) or international transfer of data.
Management of our social network: In this sense, the information collected through our social networks is used, based on Aena's legitimate interest, to:
The data processed are data identifying your profile on the social network, comments made, as well as the personal data you provide us with to resolve your issue: Name and surname, telephone number, email address, data required for the specific service (registration, reservation locator, bank details, PRM, VIP rooms, Fast Track, Fast Lane, etc.), as well as the content you generate or provide us with via private messages on our social networks.
Your data will be kept for the time necessary to comply with the purposes provided and, subsequently, will be kept duly locked, while responsibilities may arise from the fulfilment of our contractual or pre-contractual relationship, as well as for compliance with other legal obligations incumbent on Aena.
Your data may be communicated to the concessionary companies related to the services offered by Aena or even provided by them, in cases where such communication is necessary to deal with your request or incident. There are no plans for international data transfers.
How does this Policy affect me if I am also an employee of a company that works at the airport, or if I work for a company that provides services for one of the companies in the Aena Group?
How does this Policy affect me if I am either a sole proprietor or a supplier to Aena?
In this case, the companies of the Aena Group will process your data for the purpose of managing the services provided by the suppliers and customers (management of the service contracted, use of telephone and other contact means provided by the supplier for the notification of matters related to the service provided and the administrative management thereof, obligations for complying with tax regulations and management of the payment or charging of the services carried out.
In such cases, we inform you of the obligation to provide mandatory data, for the development of the contract, or data required to comply with relevant legal obligations. Otherwise, the contract cannot not be executed or signed, or Aena could not comply with its legal obligations.
The data of the company awarded the contract, of the bidding companies and of the representatives of these companies will be processed by Aena for the purpose of the proper management of the contractual and pre-contractual relationship, and on the basis of their consent expressed by signing the annexes and forms that must be provided in the bids to participate in the tender.
Likewise, the professional contact data provided may be used to establish relations with your company, basing such processing on the legitimate interest of Aena.
Who can we receive your personal data from?
In general, Aena collects personal data directly from the interested party through the application or registration forms of the different services it offers, as reported in this policy.
Sometimes, personal data may come from third parties, such as airlines, clients and collaborating companies, when it is necessary for the execution of a contract in which the interested party or their company are parties, or when there is a legal obligation to do so.
How long will we store your data for?
Your data will be retained while necessary to comply with the purpose for which they were collected.
They are subsequently stored for as long as claims and responsibilities may arise as a result of the processing of your data for the purpose for which they were collected.
Who receives your data?
In addition to those already listed above, it is anticipated that the following parties will receive your data:
To the entities of the Aena Group that will benefit from the selection processes, in the event of applying for a position for said entities, that is:
Aena, Aena Desarrollo Internacional and Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia will be responsible for the processing of your personal data that will be used to manage job applications and selection processes managed through the website. In this way, no further international transmissions or transfers of data are foreseen, except where there is a legal obligation.
What security measures are guaranteed with regards to your data?
Aena and Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia, as the data controllers, will adopt the technical and organisational measures required to guarantee the security of the personal data provided, preventing their unauthorised alteration, loss, processing or access.
How do I go about exercising my rights?
Any data subject is entitled to receive confirmation as to whether or not his or her personal data are being processed. The General Data Protection Regulation 2016/679 also stipulates the following rights for the data subject:
You may exercise your rights of access, rectification, erasure, objection, limitation of processing and portability, as well as withdraw your consent, both against Aena, S.M.E., S.A. and against Aena Sociedad Concesionaria del Aeropuerto Internacional de la Región de Murcia S.M.E., S.A., by sending an email to email@example.com or by writing to Calle Peonías, 12, 28042, Madrid, as well as through the Online Services Portal (https://serviciostelematicos.aena.es).
How do I contact the Data Protection Officer?
If you have any doubts relating to data protection, please contact our Data Protection Officer at the following email address: firstname.lastname@example.org.
Furthermore, you are entitled to lodge a complaint with the Spanish Data Protection Agency (AEPD) as the supervisory and control authority for data protection in Spain.
In the event that, as a passenger, you have voluntarily chosen to use the biometric system on the devices located at the airport, we inform you that the data collected by this system (image of your face, ID card/Passport data, boarding pass) will be used by Aena, S.M.E. S.A., with business address at C/Peonías 12, 28042 Madrid (Tax ID Number: A86212420) as data controller, in order to facilitate your transit through the airport, speed up movement through the checkpoints, security and make your identification at boarding.
This biometric system is only active for national flights of the Air Europa Airline Company, originating from Menorca Airport.
The processing is based on your consent (which can be withdrawn at any time by emailing email@example.com with a copy of your ID card/Passport, as the database is encrypted and we need this information to locate it) and in the public interest of Aena to ensure airport security.
Your data will be stored for the duration of the biometric identification service provided by Aena, and you may cancel this at any time (withdrawing your consent, as indicated above, or exercising your right to erasure).
Automated decision-making process, logic used and effects: The choice to carry out identification operations using facial recognition technology means that verification of your identity will be fully automatic. In particular, the validity of your identity document, the correspondence with the data shown on the boarding pass and the correspondence between the image of your identity document and your face will be fully evaluated. If the identification procedure is not successful, you may be delayed or denied passage through security turnstiles, passage through turnstiles to board your flight. In any case, you will have the opportunity to challenge the decision taken and to request that these checks be repeated by a security operator or by an airline operator, or to carry out this transit by traditional non-biometric means, by showing the relevant documents at each checkpoint established at each airport.
This biometric identification service is voluntary, so if you do not want to use it you can transit the airport in the traditional way presenting the corresponding documentation at the checkpoints of each airport.
Boarding Pass and ID card/Passport details have been provided to Aena by the airline company (Air Europa).
Your data may be sent to the State Security Forces for public security purposes and to the airlines to facilitate their security obligations regarding the identification of passengers and the development of transport contracts, as well as to any of the public authorities established by law. No data is expected to be transferred to another country unless required by law.
Aena S.M.E., S.A., as the data controller, will adopt the necessary technical and organisational measures to guarantee the security of the personal data you provide, avoiding its alteration, loss or unauthorised processing.
You can exercise your rights of access, rectification, erasure, objection, portability and limitation of processing, through the following email address firstname.lastname@example.org. The data can be accessed through the Online Services Portal on the Aena website (www.aena.es), or by writing to the Central Data Protection Office, Calle Peonías, 12 - 28042 Madrid. If you have any doubts relating to data protection, please contact our Data Protection Officer at the following email address: email@example.com.
A complaint may also be lodged with the Spanish Data Protection Agency at any time (www.aepd.es).