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-   -   EU GDPR / General Data Protection Reg. and FT compliance (https://www.flyertalk.com/forum/technical-support-feedback/1894419-eu-gdpr-general-data-protection-reg-ft-compliance.html)

fransknorge Feb 17, 2018 12:28 pm

EU GDPR / General Data Protection Reg. and FT compliance
 
Hello,

I would like to know what is the status with GDPR compliance Flyertalk, in general terms but specifically for
- the right to be forgotten
- the right of portability
- the right to restrict processing
- the right of correction
- contentment collection

Thanks

JDiver Feb 18, 2018 10:04 am

For members unfamiliar with the term, GDPR refers to the European Union’s latest iteration of General Data Protection Regulation, which regulates data privacy.

For more, please see this article on Wikipedia.

JDiver, Co-Moderator

IBobi Feb 21, 2018 2:39 pm

Flyertalk is a US-based site. Our TOU can be found here:

https://www.flyertalk.com/legal-notices.php

https://www.flyertalk.com/help/privacy.php

fransknorge Feb 22, 2018 12:39 am

The location of Flyertalk is not relevant as long as it has users that are located within the European Union. Please see the Wikipedia article JDiver kindly links and also this Forbes article: https://www.forbes.com/forbes/welcom...ased-business/
Or this one from the NYU https://wp.nyu.edu/compliance_enforc...personal-data/

Flyertalk is impacted by the GDPR as it has EU users. As such I would really appreciate if you could have a more precise answers to the questions in my OP please.

CPRich Feb 22, 2018 11:13 am


Use our Privacy Contact form, or write to us at the address below.

Privacy Office
Internet Brands, Inc.
909 N. Sepulveda Blvd., 11th Floor
El Segundo, CA 90245 U.S.A.

IBobi Feb 22, 2018 3:23 pm


Originally Posted by fransknorge (Post 29445060)
The location of Flyertalk is not relevant as long as it has users that are located within the European Union. Please see the Wikipedia article JDiver kindly links and also this Forbes article: https://www.forbes.com/forbes/welcom...ased-business/
Or this one from the NYU https://wp.nyu.edu/compliance_enforc...personal-data/

Flyertalk is impacted by the GDPR as it has EU users. As such I would really appreciate if you could have a more precise answers to the questions in my OP please.

I think you should read page 2 of that Forbes article.

;)

JDiver Feb 22, 2018 9:01 pm


Originally Posted by IBobi (Post 29447684)
I think you should read page 2 of that Forbes article.

;)

This?


The organization would have to target a data subject in an EU country. Generic marketing doesn’t count. For example, a Dutch user who Googles and finds an English-language webpage written for U.S. consumers or B2B customers would not be covered under the GDPR. However, if the marketing is in the language of that country and there are references to EU users and customers, then the webpage would be considered targeted marketing and the GDPR will apply.

fransknorge Feb 23, 2018 12:12 am

Considering some of the ads I see are in German, and I do live in Germany, then I would say this is targeted marketing.
So again, I maintain my position that Flyertalk has to comply to the GDPR and i would appreciate if they could share with their thousands of European customers their plan.
And I am not the only one to think so:

The GDPR applies to organizations involved in the processing of personal data of individuals located in the EU. “[P]ersonal data” is defined broadly as “any information relating to an identified or identifiable natural person.”

[3] “Processing” means “any operation or set of operations which is performed on personal data or on sets of personal data.”[4] These are broad definitions encompassing a range of data types and a variety of data usages—they are designed in particular to sweep in U.S. technology companies. Indeed, information such as log-in information, IP addresses, and vehicle identification numbers, though not enabling direct identification of individuals, allow for identification of individuals indirectly and are therefore considered to be personal data.

fransknorge Feb 23, 2018 12:20 am

https://cimg6.ibsrv.net/gimg/www.fly...fc23462bc0.png

Example of ad I see now. It is not in German but clearly targeted as I am currently in FRA and thus is explicitly for the EU market.

lo2e Feb 23, 2018 5:06 am


Originally Posted by fransknorge (Post 29448947)
Considering some of the ads I see are in German, and I do live in Germany, then I would say this is targeted marketing.
So again, I maintain my position that Flyertalk has to comply to the GDPR and i would appreciate if they could share with their thousands of European customers their plan.
And I am not the only one to think so:

I think you're taking "targeted marketing" WAY too liberally here. FT does not sell products, IJAFBB. Yes, there are advertisers who market to where you are, but that then makes them the ones who are doing the "targeted marketing", not FT.

CPRich Feb 23, 2018 10:05 am


Originally Posted by fransknorge (Post 29448947)
i would appreciate if they could share with their thousands of European customers their plan.

I provided the contact information above. Is something preventing you from contacting the Privacy office to understand privacy, preferring to discuss with website administrators?

fransknorge Feb 24, 2018 7:17 am

It would build trust if IB staff publicly explain how IB intent to comply with regulations concerning the handling and processing of customer private data.
This is an opportunity for IB to show their intent to follow regulations.

fransknorge Feb 24, 2018 7:18 am


Originally Posted by lo2e (Post 29449507)
I think you're taking "targeted marketing" WAY too liberally here. FT does not sell products, IJAFBB. Yes, there are advertisers who market to where you are, but that then makes them the ones who are doing the "targeted marketing", not FT.

You might want to read the regulations.

gobluetwo Feb 24, 2018 10:19 pm


Originally Posted by fransknorge (Post 29453133)
It would build trust if IB staff publicly explain how IB intent to comply with regulations concerning the handling and processing of customer private data.
This is an opportunity for IB to show their intent to follow regulations.

Sure, but remember also that FT is just one of dozens of sites owned by IB. It would be best, imo, to contact IB directly, as any statement or interventions regarding GDPR would likely be applicable across all (or at least many) of their sites.

I wouldn't necessarily expect a website administrator to be the point of contact for matters related to privacy policies, particularly given that GDPR still has some pieces which are yet to be fully defined.
You could also try calling them. The numbers I get back from a web search are 310-280-4000 and (800) 692-2200. Although that particular avenue may be more difficult since you're in Germany.

lo2e Feb 25, 2018 5:57 am


Originally Posted by fransknorge (Post 29453137)


You might want to read the regulations.

I did. I stand behind my statement unless you can find a regulation that says I'm incorrect.

IBobi Feb 26, 2018 11:54 am

I am awaiting word from my legal team on this, and if they state differently, I'll post here.

fransknorge Feb 26, 2018 12:21 pm

My understandin is that, however, FT is the data controller for the ads providers it uses and therefore has responsibilities there. Also FT does collect personal data (email, iP addresses) and then rights to access, correct and delete apply.
Thanks for passing this to your legal team, I am looking forward to their answer.


fransknorge Mar 27, 2018 5:58 am

Any update on this, please ? Did the legal team reached any conclusions ?

lo2e Mar 27, 2018 7:04 am

Curious what your stake in this discussion is. You seem to be very passionate about this particular topic, and so far seem to be the only one here on FT who is (or if there are others, they haven't posted here like you have).

Originally Posted by fransknorge (Post 29571953)
Any update on this, please ? Did the legal team reached any conclusions ?

Did you do what was already suggested by gobluetwo?

Originally Posted by gobluetwo (Post 29455486)
It would be best, imo, to contact IB directly, as any statement or interventions regarding GDPR would likely be applicable across all (or at least many) of their sites.

I wouldn't necessarily expect a website administrator to be the point of contact for matters related to privacy policies, particularly given that GDPR still has some pieces which are yet to be fully defined.
You could also try calling them. The numbers I get back from a web search are 310-280-4000 and (800) 692-2200. Although that particular avenue may be more difficult since you're in Germany.


fransknorge Mar 27, 2018 11:59 am

I trust FT with my personal data. Considering the climate those days around misuse of those, I want FT to reassure me, their customer, that they will follow the relevant regulations and ensure the third party they are using, like ad providers will also do so. My stake are my personal data.

RichardInSF Apr 25, 2018 9:35 pm

Regardless of what the FT legal team (most likely expert only on US law) says, it would behoove FT to take the GDPR rules seriously.

Consider it a dry run for similar rules being adopted here in the USA. Admittedly, that's not likely to happen during the term of the current administration but all that means is that FT will have enough time to get their response right.

gobluetwo Apr 26, 2018 8:51 am


Originally Posted by RichardInSF (Post 29684546)
Regardless of what the FT legal team (most likely expert only on US law) says, it would behoove FT to take the GDPR rules seriously.

Consider it a dry run for similar rules being adopted here in the USA. Admittedly, that's not likely to happen during the term of the current administration but all that means is that FT will have enough time to get their response right.

Does FT have a dedicated legal team, or does Internet Brands have a legal team which covers FT, among other of their properties?

I don't understand the OP's reluctance to contact Internet Brands directly. If you click on the Privacy Policy at the bottom of this page, it goes directly to an IB page. FT does not have a separate privacy policy apart from what IB has. It stands to reason that IB is the one to contact, not FT moderators or admins.

starflyergold Apr 26, 2018 9:53 am

fransknorge is absolutely correct to inquire about GPDR and how it relates to FT. The world of online privacy is changing, especially for EU citizens. The location of the data controller is irrelevant. FT (or to be precise IB as the owners) holds data on each user which needs to be brought inline with GPDR and be clear how the data subject (FT members) can access or request deletion of this data. I'm not surprised that IB is woefully unprepared for GPDR, very few companies are, including in the EU, despite the long lead in time.

I don't think it is true to say it is only fransknorge who is passionate about this, I for one would share his concern. For me this is not a criticism of the IB management (though I would question reliance on a Forbes article :rolleyes:), it is a strong encouragement to prepare and act on legal obligations (that extend beyond the borders of the EU). And yes mods have no role in this in case anyone is wondering.

IBJoel Apr 26, 2018 2:37 pm

Hi everyone,

I spoke to our ad team today. Part of the reason for the recent FT upgrade was GDPR compliance. So as far as the ads go, FlyerTalk is ready to go, as of this month. Note that some things might not fully roll out until the implementation date in late May.

JDiver Apr 30, 2018 10:07 am

1 Attachment(s)
As Internet Brands has taken this issue under advisement and has implemented GDPR implementation, the thread has been closed to discussion.

It’s implementation as mentioned by IBobi has occurred, as noted in a forum Announcement displayed below (as well as at the top of the page during its implementation period).

Thanks to franksnorge for starting the thread and “getting the ball rolling”, and to starflyergold for nudging.

JDiver, Co-Moderator, Technical Support and Feedback forum


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