topbonus privacy policy

topbonus Ltd., as the operator of the topbonus Program (hereafter referred to as "topbonus") takes the protection of your privacy seriously. The following information should provide you with an overview and the greatest possible transparency about the data processing procedures in our topbonus Program. topbonus Ltd. is the party responsible for the collection, processing and utilisation of your personal data in connection with the topbonus Program and the topbonus website ( »). You can view the collection and use of your data, which is done independently of your participation in the topbonus Program, by Air Berlin PLC & Co. Luftverkehrs KG, at »

I. Your data in the Program implementation

If you participate in the topbonus Program, we will need your form of address, full name, date of birth, complete address, e-mail address, and a username and password you choose so that we can identify and communicate with you. To improve communication, you can voluntarily inform us of your title, additional address, and your preferred language. Fields that must be filled out in order to participate are marked with an * (mandatory fields).

Your data will be collected, saved, and used by topbonus (contact ») as the responsible party for managing the topbonus Program. In particular, air Berlin is responsible for sending your valid topbonus Card and password if you register by postal application or by telephone, crediting collected miles, managing your account, sending the current account balance (at the discretion of topbonus either by e-mail or by regular mail) and redeeming award miles.

During the implementation of the topbonus Program, the following additional data will be collected, saved, and used for the same purposes: Operations that are credited or redeemed by the miles, as far as they are necessary to accurately determine the mileage credit, such as flight route, flight date, flight number, operating airline and booking class. You can find a precise description of the collection and redemption of miles in clause 2 of our Terms and Conditions at »

II. Sending of information

In addition, we will use your data to send you information about similar topbonus Program services by mail or e-mail. You can revoke the use of your e-mail and/or postal address for such advertising purposes at any time.

When you register, you can agree to receive e-mails containing general information and information tailored to your interests, as well as current offers from topbonus and its partner companies in the topbonus Program. The current partner companies can be seen at ». You can revoke your consent at any time.

You can declare your objection or revocation in your topbonus profile » or - if applicable - in the newsletter, without having to pay more than your normal service charge when declaring your revocation by e-mail or through the topbonus website.

III. Disclosure of your personal data to third parties

If you book services with partner companies (flights, rental cars, overnight stays, purchases with an topbonus credit card, etc.), your personal data will be transferred to the corresponding company or directly collected by the partner company in order to enable topbonus to credit the miles.  If the data is collected by the partner company (for example by the car rental-, hotel-, or banking-partner), this company shall be the responsible party within the meaning of the Federal Data Protection Act. The transfer is limited to data that is required to correctly credit miles. This data basically includes: First and last name, frequent flyer number and booking dates (for flight bookings e.g., flight number, flight date, point of departure, destination, booking class; for hotel bookings e.g., check-in date, town; for car rental bookings, e.g., date of rental, place of rental).

topbonus reserves the right to plan promotional campaigns jointly with its topbonus partners and to use your address data for such purposes, provided that you have not revoked this use. Service providers hired by topbonus handle the advertising, so your data will not be transferred to the partner company.

topbonus can entrust service providers with tasks and transfer personal data for such tasks, provided this is necessary for administering the program. Likewise topbonus can contract third parties to collect, process or utilise personal data for topbonus, as an external data processing service.

In case Air Berlin PLC & Co. Luftverkehrs KG collects personal data related to the topbonus Program as part of the booking process, this also happens for topbonus for the purpose of implementing the topbonus Program.

IV. Transfer of data to countries outside the EU

Your data will only be transferred to countries outside of the EU as part of the topbonus Program to the extent necessary for collecting and / or redeeming award miles for airlines, rental car- or hotel-partners or additional partner companies through which miles can be collected. The transfer is limited to data that is required to correctly credit miles. This data basically includes: First and last name, frequent flyer number and booking dates (see above).

V. topbonus Service Card

If you have a topbonus Service Card, your data will be used to draw up and conclude the contract.

topbonus Visa Card / topbonus & Niki Visa Card / topbonus EURO 6000 MasterCard (“topbonus credit cards”)

If you apply for an topbonus credit card, your data will be collected and used pursuant to the guidelines of the credit card issuer; in Germany, this is the Landesbank Berlin AG and in Austria the Raiffeisen Bank International AG. The guidelines are described in more detail in the application process.

If you apply for the topbonus credit card during the flight booking process or through the topbonus website, your personal data will be transferred according to the consent your granted when you applied.

The credit card contract is made between you and the financial service provider that issues the credit card; there is no credit card contract between you and topbonus.

VI. Cookies

By using  this website you accept that cookies are used as described below and that the pseudonymised data is saved for the purposes stated below even after your visit to the website has ended. 

Permission to collect and store data using cookies may be revoked at any time with future effect by adapting your browser settings in such a way that your browser refuses to accept cookies. 

1. Web analysis, Retargeting, Third party cookies

Cookies are small text files that are stored locally in the cache of the website visitor’s internet browser. Cookies allow the internet browser to be recognised. There are different kinds of cookies, on the one hand, so-called session cookies, which are deleted once you close your browser, and on the other hand, temporary/permanent cookies, which are stored on your data carrier for a longer period of time or permanently.

On the one hand, topbonus uses session cookies, which are automatically deleted from the visitor’s hard drive at the end of the browser session (end of the visit to the website). Session cookies are needed, for example, to enable customers to make flight bookings which extend over several pages. 

In addition to this, topbonus also uses cookies which are stored for a longer period of time on the website visitor’s hard drive. When this website is visited the next time, these cookies then recognise that the user has visited the site before and which entries and settings were given preference on previous occasions. These temporary or permanent cookies (which may have a lifetime of up to a year) are saved on the hard drive and are deleted automatically at the end of the specified time. These cookies are intended to make this websites more user-friendly, more effective and more secure and to help them meet customers’ needs in the best possible way. In order to do this, they make it possible, without personally identifying the website visitor, to address targeted advertising to each internet browser, where an interest has already been shown in certain products. When a cookie is activated it is assigned a user ID. Personal data such as name, IP address or similar data are not associated with this user ID in any way and this is also not the intention. Only pseudonymised data is collected and saved using this cookie technology, such as which products are searched for, viewed or selected. On our websites technologies supplied by, e.g., etracker GmbH (, doubleclick ( or Google Analytics ( are used. These record information on topics such as which web pages you have visited in the past or which products you have shown an interest in, so that adverts can be displayed which correspond as far as possible to the interests of the website visitor, without, of course, allowing the pseudonymised data to be linked to personal data.

It is possible that the data you have entered may be shared and used by third party suppliers through third party offers which we make available. This will also only happen in anonymised form and no link can be made at any time to your personal data. We work with various advertising partners on the basis of retargeting technologies. These help us to constantly improve the product and services we offer. In particular it allows us to address any internet browser which has already shown interest in our products with promotion campaigns, without personally identifying the visitor to the respective website. Studies have shown that displaying interest-based advertising holds more appeal for internet users than advertising which is not necessarily related to the user‘s interests. With retargeting, the display of promotional material is related to a cookie-based analysis of behaviour on previous visits, when a user profile was created under a pseudonym. On our websites technologies supplied by the following advertising partners are used: criteo (, YD World (, adara media (

Permission to collect and store data using cookies may be revoked at any time with future effect by disabling the use of cookies for the respective supplier via the following links: 

•   YD World

2. Social Plugins

In addition social plugins from the social networking site (which is run by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) are used ("Facebook"). These plugins are identified by a Facebook logo or the phrase "Facebook Social Plugin". When you access a page on our website that contains one of these plugins, your browser sets up a direct link to the Facebook server and Facebook transmits the content of the plugin directly to your browser, which then integrates the content into the web page. This means that Facebook is informed that you have accessed the particular page of our website. If you are logged into Facebook, Facebook can map the visit to your Facebook account. When you use one of the Facebook plugins, for example the "Like" button or you post a comment, information to this effect is sent directly from your browser to Facebook and saved there. Please read Facebook’s privacy policy » to learn more about the purpose and amount of data collected, about the further use or distribution of the data by Facebook and about your rights in this respect and how to protect your privacy.

VII. Contact

You can contact topbonus at any time if you have questions about or suggestions for our data protection regulations. Likewise, you can inquire at topbonus at any time
as to what personal data topbonus has saved about you and have such data corrected or deleted/blocked accordingly. Our goal is to guarantee the greatest possible security and confidentiality.