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Privacy Policy


Effective: 29 July 2020

Introduction

Welcome to Jet Connections. (“JetCon”, “We”, “Us” and “Our”). JetCon utilizes assorted software applications “Software” to effectively execute and follow up transactions with our ad hoc charter and aircraft management clients “Clients” related to the different services we provide “Services” whether directly or through our suppliers “Suppliers”, subject to understandings, agreements or contracts “Contracts” between us and our clients, or any other related matters.

The “Website” means JetCon’s website (including without limitation any successor URLs, mobile or localized versions, related domains and subdomains; and associated social media outlets), and the “Services” means JetCon’s products, applications and services, in each case in whatever format they may be offered now or in the future.

Purpose

The purpose of this “Privacy Policy” is to inform you of the type of personal data we collect when you use our Services, why we collect the data, how it is used and your rights and choices. If you do not agree with this Privacy Policy, the onus is on you not to access or use our Services.

Personal Data Collected

When you use our Services, we collect personal data about you, described below. The term “Personal Data” means any data that enables a person to be identified. Specifically, Personal Data that you provide to us for the purpose of facilitating and legalizing the process of service provision. We collect Personal Data that you provide to us when you sign a contract with us and/or register for an account, such as your family name, first name, profile photo, postal address, email address, telephone numbers, date of birth, data relating to the services you order under the contract as well as any other information about you that you make available to us.

We also collect the information that you may choose to submit to our staff, our representatives, or Suppliers, for example regarding a problem you are experiencing with our Services. This may include your contact information, a summary of the problem you are experiencing, and any other documentation or information that would be helpful in resolving the issue.

Automatically Collected Data

When you interact with Us through the Services, we automatically collect information about you through cookies (small text files placed on your device), mobile device identifier and other technologies. Please read the “Cookies” section below to learn more about how we use cookies and other technologies. When you visit our Website, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Website. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you access the website), browser type and settings, the date and time of your request.

Data Collected in Relation to Payments

JetCon and its online payments processing partners, hereby state that:

  • All credit card/debit card details and personally identifiable information will NOT be stored, sold, shared, rented, or leased to any third parties.
  • The Website Policies and Terms & Conditions may be changed or updated occasionally to meet current requirements and standards. Therefore, the Customers/Clients are encouraged to frequently visit these sections in order to be updated themselves about the changes on the website. Modifications will be effective on the day they are posted.
  • Some of the advertisements you see on this website are selected and delivered by third parties, such as ad networks, advertising agencies, advertisers, and audience segment providers. These third parties may collect information about you and your online activities, either on this website or on other websites, through cookies, web beacons, and other technologies in an effort to understand your interests and deliver to you advertisements that are tailored to your interests. Please remember that we do not have access to, or control over, the information these third parties may collect. The information practices of these third parties are not covered by this privacy policy.
  • Any dispute or claim arising out of or in connection with this website shall be governed and construed in accordance with the laws of England.
  • Our country of domicile is the UK.
  • Minors under the age of 18 shall are prohibited to register as a User of this website and are not allowed to transact or use the website.
  • If you make a payment for products or services on or through our website, the details you are asked to submit will be provided directly to our payment provider via a secured connection.
  • The cardholder must retain a copy of transaction records and Merchant policies and rules.
  • We accept payments online using Visa and MasterCard credit/debit cards in any agreed currency.
  • JetCon will NOT deal or provide any services or products to any country that is under sanctions by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury and will observe and abide by any laws enacted in this regard by the UK.
  • As our products and services are not fixed and are of an ad hoc nature affected by numerous parameters (the type of aircraft, destination, duration of stay, additional services requested, etc.), they are therefore based on prior quotation and once accepted, both parties enter into an agreement before the product or service is provided or rendered
  • Multiple transactions may result in multiple postings to the cardholder’s monthly statement.

Use of Personal Data

We collect Personal Data for the following reasons:

  • To provide the Services and manage your access and use of the Services, including to process transactions with you, authenticate you when you log in, provide customer support, operate, and maintain the Services, follow-up of the customer relations. This processing is necessary to perform the contract with you or to take steps prior to entering into a contract at your request, or it is necessary for our legitimate interests in responding to your requests.
  • To communicate directly with you, including sending you newsletters, promotions and special offers or information about current products, current services, new products, and services. This use of your data is in our legitimate interest in communicating with our clients about our products and services. You may at any time opt-out of receiving such communications by (i) clicking the unsubscribe link included in all the emails you receive or (ii) contacting us as indicated under “Contact” section below. We will send you other information on our new products or services or other promotions only with your consent (and you have the right to withdraw your consent at any time).
  • To comply with our legal and regulatory obligations.
  • As necessary for certain legitimate business interests, which include the following:
  1.  
    1. To better understand how visitors, interact with our Services and ensure that our Website is presented in the most effective manner for you, and as part of our efforts to keep our Website, network, and information systems secure.
    2. For providing, maintaining, protecting, developing, benchmarking, and improving JetCon’s offerings, in particular resolving any bugs and fixes, enhancing, or improving features of existing products and developing new products and capabilities.
    3. To conduct analytics to enhance our marketing strategy and enable us to personalize our communications and the experience we offer to our users.
    4. To manage unpaid invoices and possible disputes about the use of our products and services.
    5. To share Personal Data within our affiliates and subsidiaries for internal administrative purposes.

Deletion of Personal Data

If you request us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing.

We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.

As used above, “legitimate interests” means our interests in conducting our business, managing, and delivering the best Services to our Clients.

Terms of Use of Personal Data

We will not use your Personal Data for activities where the impact on you overrides our interests unless we have your consent, or those activities are otherwise required or permitted by law.

We also use Personal Data about you where you have given us consent to do so for a specific purpose not listed above. For example, with your permission, we may publish testimonials or featured client stories on our Website to promote the Services, including names and profile photos of representatives of our clients alongside the testimonials.

We will inform you when requesting your Personal Data, if certain data must be provided or if it is optional. We will also inform you of the consequences should you not wish to provide this data.

While providing our Services, we may collect on behalf of our clients’ information related to our clients’ employees, and other individuals. Our use of information on behalf of our clients is governed by our contract with the relevant client. We are not responsible for the privacy policies or privacy practices of Clients or other third parties.

Jet Connections and GDPR

This section applies if you are an individual in the UK and EU (for these purposes, the reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein, and Norway and, to the extent applicable, Switzerland). JetCon is compliant with the UK and EU General Data Protection Regulation (mostly referred to by the acronym GDPR).

JetCon is the data controller for processing your Personal Data. We act as a data processor (or service provider) in relation to the Services we provide to our clients.

To find out our registered office and how to contact us, please see the “Contact” section below.

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of personal data, username, password, and other data stored on our servers.

Sensitive and private data exchanges between JetCon and its Clients and Suppliers happens over a TLS secured communication channel (also known as SSL) and is encrypted and protected with digital signatures.

We may be partnered with various providers to offer a reliable service. All of our partners have a great security track-record, take personal data privacy seriously, and are fully compliant with GDPR.

Your Rights

Subject to UK and EU data protection law, you have the following rights in relation to your Personal Data:

  • Right of access:

If you ask us, we will confirm whether we are processing your Personal Data and if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.

  • Right to rectification:

If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.

  • Right to erasure:

You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.

  • Right to restrict processing:

You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restrictions on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.

  • Right to data portability:

You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you where we process that Personal Data in an automated way. We will give you your Personal Data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere.

  • Right to object:

You may ask us at any time to stop processing your Personal Data, and we will do so:

If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or

If we are processing your Personal Data for direct marketing (you can always object using the unsubscribe link in our marketing communications).

  • Right to withdraw consent:

If you have consented to our use of your Personal Data for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing of your data that has already taken place.

  • Right to make a complaint with the data protection authority:

If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

To learn more about the GDPR, please, visit the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en

Disclosure of personal data

  • Personnel, Service Providers:

Only our personnel, service providers and trusted third parties have access to your Personal Data. These parties include hosting, back-up and other IT services providers, website analytics companies, providers of digital advertising services, providers of CRM, marketing and sales software solutions, billing, and processing payment functions. We only provide such parties with the information they need to perform the services we have hired them to provide.

  • Our Subsidiaries and Affiliates:

We share your Personal Data with our subsidiaries and affiliates for internal administrative purposes, in accordance with this Privacy Policy (this sharing is in our legitimate interest).

  • Legal Requirements:

We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or lawful requests by public authorities, including to meet national security or law enforcement requirements, (ii) protect and defend the rights, staff, or property of JetCon, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

  • Business Transfers:

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

  • With Your Consent:

We may share Personal Data about you with third parties when you give us consent to do so. For example, with your permission, we may publish and display testimonials or featured customer stories on our Website, including names and profile photo of representatives of our customers alongside the testimonial.

Data Retention

JetCon may retain your Personal Data for a period of time consistent with the original purpose of collection. For instance, we may retain your Personal Data during the time you have an account to use our Website or Services, or as agreed in our subscription agreements, and for a reasonable period of time thereafter. We also may retain your Personal Data as necessary to comply with our legal obligations, to establish proof of a right or a contract, resolve disputes, enforce our agreements, in accordance with the law.

Data Security

We take all necessary precautions, as well as appropriate organizational and technical measures, to maintain the security, integrity, and confidentiality of your Personal Data, and in particular to prevent it from being altered or damaged and to prevent any unauthorized third party from accessing it. We also use secured payment systems consistent with the state of the art and the applicable laws and regulations. 

Cookies

Cookies are small text files that are placed on your computer or mobile device when you visit a website, mobile app or use an online platform. Cookies are widely used by online service providers to facilitate and help to make the interaction between users and the Website, mobile apps, and online platforms faster and easier, as well as to provide reporting information. For more information about cookies and their impact on you and your browsing visit www.aboutcookies.org

Cookies set by the website and/or mobile app and/or platform owner (in this case, JetCon) are called “first party cookies”. Cookies set by parties other than the website and/or mobile app and/or platform owner are called “third party cookies”. Third-party cookies enable third party features or functionality to be provided on or through the website and/or mobile app and/or platform (e.g. like advertising, interactive content, and analytics). The parties that set these third-party cookies can recognise your computer or device both when it visits the Website and/or mobile app and/or platform in question and also when it visits certain other websites and/or mobile apps and/or platforms. By choosing to use our Website after having been notified of our use of cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

Why Do We Use Cookies?

We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website and/or App and/or platform to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Website and/or App and/or platform. Third parties serve cookies through our Website and/or App and/or platform for analytics and other purposes. This is described in more detail below.

Our Website’s Cookies

Purpose:      

Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website and to use some of its features.

Vendor:

Jet Connections.       

How to refuse:

Because these cookies are strictly necessary to deliver the Website and the Services to you, you cannot refuse them.

Analytics and Customization Cookies:

Purpose:

These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customise our Website to better suit your needs.   

Vendor:

Google Analytics.    

How to refuse:

To refuse these cookies, please follow the instructions below under the heading “Managing Cookies” Alternatively, please click on the relevant opt-out link below:
Google Analytics

Managing Cookies:

Most internet browsers allow you to erase cookies from your computer’s hard drive, block all cookies (or just third-party cookies) or warn you before a cookie is stored on your device. Please note, if you choose to block all cookies, our site will not function as intended, and you will not be able to use or access many of the services we provide. If you have blocked all cookies and wish to make full use of the features and services we offer, you will need to enable your cookies. You can do this in your browser. Rather than blocking all cookies, you can choose only to block third-party cookies which will still allow our website to function as intended.

Modifications:

We reserve the right, at our sole discretion, to modify this Privacy Policy or any portion thereof.

Any changes will be effective from the time of publication of the new privacy policy. If we believe that the changes are material, we will let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes.

Your continued use of the Services after the changes have been implemented shall indicate your agreement with the terms of such revised privacy policy. Otherwise, and if the new privacy policy does not suit you, you must no longer use the Services.

Contact Us:

If you have questions or concerns about our privacy policy, please contact us by email or post as follows:

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Post:

Jet Connections LTD

London Oxford Airport

Kidlington

OXON

OX5 1RA

United Kingdom