Date effective: September 2021

1. This Privacy Policy

All information described in this Privacy Policy is processed by Delta Air Lines, Inc. ("Delta", "we", "us", or "our") as data controller. This Privacy Policy describes our practices related to the use, storage, and disclosure of personal information we collect from or about you when you interact with us in the course of our providing commercial air travel services, ancillary services, or other services provided by us or by others acting on our behalf, including when you use our website Delta.com ("Website") or our Fly Delta App ("App"). This Privacy Policy also describes our processing of the personal data of individuals representing our business customers and suppliers.

Delta reserves the right to modify this Privacy Policy at any time and without prior notice. We will post any changes to our Website. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

2. How to Contact Us

Delta has a Privacy Team, including a Data Protection Officer, that is dedicated to protecting your privacy. If you have any questions or comments regarding this Privacy Policy or any complaints about our adherence to it, please contact our Data Protection Officer, Renee Lopez-Pineda, at Privacy@delta.com or contact our Customer Care Center by telephone or mail. We adhere to applicable notification requirements and reporting obligations to supervising authorities and/or data subjects regarding violations of this Privacy Policy as required by law. The substance and time frames applicable to these remedies are set forth in applicable laws.

Additional remedies available in the event of a perceived violation of your privacy rights are discussed in sections 9.7 and section 12 regarding information security safeguards and data breach notification procedures.

3. How Does Delta Collect & Receive Your Information?

3.1 We collect information from you

We may collect and receive information from you, including when you:

• Use or access our Website or App, such as when you complete the "passenger details" section during the course of a booking, even if you do not complete the booking;
• Register, create, or modify an online or in-app account with us, including your SkyMiles Partners account and Promotional Partners account, or any account to use our online corporate travel tool(s), communicate with us by email, including when you email us at Privacy@delta.com, telephone, in writing, through our customer services pages, or social media;
  • Our SkyMiles Partners are hotel, car rental, shopping, dining, vacation, and other businesses with whom you can earn, transfer, or redeem miles in the SkyMiles Program or otherwise qualify for discounts or benefits in connection with SkyMiles membership or Medallion Status. Our Promotional Partners are businesses with whom you may be offered a discount or benefit as a result of your transactions with Delta.
• Use any of our services, including when you travel with us, use airports where we operate, or use any facilities, such as Delta Sky Club lounge facilities, within those airports;
• Through cookies and other tracking technologies on our Website and App (see section 6 below); and
• Are associated to a company we do business with

3.2 Automatic access and data collection from our App

• Our App may access certain device information and/or components automatically.

3.3 We collect information from other sources

• We may receive your personal information from other airlines, and from travel agencies and your employer or company in connection with your travel booking.
• We may also receive your personal information from SkyMiles Partners and Promotional Partners in connection with our SkyMiles Program.
• Our suppliers and other businesses we deal with provide us personal information of their representatives.
• This Privacy Policy applies to information we receive from those other sources, as well as to information we collect from you or generate about you. Delta is committed to limiting the information collected to what is necessary for the purposes for which the information is collected.

4. How Delta Uses Your Data

4.1 Information about you and how we use it

• This section describes what personal information we collect about you, the purposes for which we use it, and for purposes of the European Union General Data Protection Regulation ("GDPR"), the retained version of the GDPR ("UK GDPR") in the United Kingdom ("UK"), the UK Data Protection Act 2018 and other applicable law, the legal basis pursuant to which we process the information. Please also see section 4.2 regarding information collected through our App, and section 4.6 regarding our use of sensitive types of information.

4.1.a

Information related to a flight booking or purchase of our products or services, whether provided on line, over the phone, in person, at an airport kiosk or self-service device, in flight, or otherwise, and whether bought privately or through your employer or company including:

• your name and title;
• your national ID, in certain circumstances;
• your contact details, such as postal address, telephone numbers, and email address;
• your flight, luggage, boarding and other ticketing information, such as bag tag tracking number and luggage screening information, including X-ray images of checked luggage;
• special assistance requests and preferences;
• your billing and transaction information such as credit/debit card type and number(s), corporate forms of payment, and related data including associated billing address, and expiration date(s);
• emergency contact(s);
• seating preferences, medical needs, and dietary requests;
• flight, car, and hotel preferences;
• travel companions’ personal information;
• information about who is meeting or dropping you off;
• your order for other services, such as cargo, animal services, and inflight services such as upgrades, beverages/food, and goods;
• any employer or company information associated with your booking;
• your reason for travel.

We use this information to:

• provide you with your flight and other products and services;
• provide assistance with bookings and seat assignments including where relevant for our corporate travel program passengers, in cooperation with their corporate travel managers;
• confirm your travel arrangements and remind you about incomplete bookings;
• take your payment and make any refunds or credits and send any confirmations;
• send you service communications, such as notifications of flight schedule changes, and check-in opening;
• manage and administer our services and business, including performing our record-keeping requirements;
• maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
• improve our products and services, including through statistical analysis and research for program development;
• send you marketing communications, offers, and invitations to events, which may be based on our segmentation and modelling of your personal information;
• provide you with assistance in an emergency, including communicating with your emergency contacts;
• share it with other airlines for the purposes of your itinerary or re-booking you if there is a travel disruption;
• share it with our SkyMiles Partners and Promotional Partners for the purpose of their providing services to you;
• share it with authorized government agencies and as otherwise described in section 7.
• share it for luggage security screening to enable you to travel within and between countries.
• tailor our products and services for you, including anticipating your likely preferences based on information concerning your previous travel with us, previous transactions, or communications with us, any of which we may combine with other information we have about you, and which may be based on our segmentation and modelling of your personal information.