Privacy Policy

Last updated: [date]

 

This Privacy Policy explains how Alary Jet ("Alary Jet", "we", "us", "our") collects, uses, shares and protects personal data when you visit www.alaryjet.com (the "Website"), request a quote, book or take a flight with us, or otherwise communicate with us.

 

1. Who we are

Alary Jet is the organisation responsible for your personal information under Bermuda's Personal Information Protection Act 2016 ("PIPA"). Where we offer our services to, or process the personal data of, individuals in the European Economic Area or the United Kingdom, the EU General Data Protection Regulation (Regulation (EU) 2016/679) or the UK GDPR (together, the "GDPR") may also apply, and we comply with it to that extent. In this Policy, "personal data" and "personal information" have the same meaning.

•  Company: Alary Jet [legal form]

•  Registered office: [registered address]

•  Company number: [company number]

•  Email: info@alaryjet.com

•  Telephone: +351 929 383 463

 

We have appointed a Privacy Officer, as required by PIPA, who is responsible for our compliance with this Policy. If you have any question about this Policy or how we handle your data, please contact our Privacy Officer at [privacy email, e.g. privacy@alaryjet.com] or info@alaryjet.com, with the subject line "Privacy".

 

2. Personal data we collect

We collect only the personal data we need to answer your enquiry, arrange and operate your flight, and meet our legal and regulatory obligations.

 

2.1 Data you give us

•  Quote requests: first and last name, email address, telephone number, route, travel dates, trip type, number of passengers, how you heard about us, how often you fly privately, and any comments you add.

•  Bookings and flights: full names, dates of birth, nationality, passport or identity document details and visas of every passenger, contact details of the lead passenger or booker, billing and invoicing details, catering and ground transport preferences, and baggage, pet or special equipment details.

•  Special requirements: where you choose to tell us about a medical condition, reduced mobility or dietary requirement so that we can travel you safely and comfortably. This is sensitive personal information and we only use it with your explicit consent, or where necessary to protect your vital interests or to comply with a legal obligation.

•  Communications: the content of emails, calls and messages you exchange with us, and your marketing preferences.

 

2.2 Data we collect automatically

When you use the Website, our hosting provider and its technologies record technical data such as your IP address, browser type, device, pages visited and the time of your visit. The quote search stores your selected trip in your browser's local storage so that it can be shown on the quote page; it is removed once your request has been sent. See section 9 (Cookies and similar technologies).

 

2.3 Data from third parties

We may receive data about you from a person who books a flight on your behalf (for example, your assistant, company or a travel adviser), from brokers and partner operators, and from public sources and screening lists we are required to check.

 

If you give us personal data about other passengers, you confirm that you are authorised to do so and that you have informed them of this Policy.

 

3. How we use your data and our legal basis

We use personal data only where one of the conditions permitted by PIPA applies and, where the GDPR applies, on the corresponding lawful basis shown below.

•  To answer your quote request and prepare a proposal: steps taken at your request before entering into a contract (PIPA contract condition; GDPR Art. 6(1)(b)).

•  To confirm, organise and operate your flight, including crew briefing, catering, ground handling, fuel and permits: performance of our contract with you (PIPA contract condition; GDPR Art. 6(1)(b)).

•  To send passenger and crew information to airports, border, customs, immigration and security authorities, to keep flight, safety and operational records, and to meet tax, accounting and aviation regulatory obligations: compliance with legal requirements (PIPA legal-requirement condition; GDPR Art. 6(1)(c)).

•  To manage payments, prevent fraud, protect the safety and security of passengers, crew and aircraft, and establish or defend legal claims: uses you would reasonably expect and that do not adversely affect your rights (PIPA), or our legitimate interests (GDPR Art. 6(1)(f)).

•  To improve our Website and services and understand how clients find us: uses you would reasonably expect (PIPA), or our legitimate interests (GDPR Art. 6(1)(f)).

•  To send you news and offers by email, and to contact you by text message: your consent (PIPA; GDPR Art. 6(1)(a)), which you may withdraw at any time.

•  To take account of health or accessibility information: your explicit consent, or where necessary in an emergency to protect life or health (PIPA; GDPR Art. 9(2)(a) and (c)).

 

We do not sell your personal data, and we do not make decisions about you based solely on automated processing.

 

4. Who we share your data with

We share personal data only where necessary and, where the recipient acts on our behalf, under a written contract that protects your data. Recipients may include:

•  Service providers that help us run our business: website hosting (Wix.com), our form delivery service (Web3Forms), email and IT providers, payment providers and our professional advisers.

•  Aviation service partners needed for your flight: ground handling agents, fixed-base operators, airports, catering, ground transport and hotel providers, flight planning and permit providers.

•  Partner air operators, where your flight is operated or sub-chartered by another duly licensed operator (see our Terms & Conditions).

•  Public authorities: civil aviation, border, customs, immigration, police and security authorities, where required by law.

•  Insurers, and courts or parties to a dispute, where necessary to establish, exercise or defend legal claims.

•  A buyer or successor, if our business or assets are reorganised or transferred.

 

5. International transfers

Private aviation is international by nature. To perform your flight we must share certain data with recipients in the countries your flight departs from, arrives in or overflies, and some of our service providers process data outside Bermuda.

 

When we transfer personal information to an overseas third party, we remain responsible for it under PIPA. We assess the level of protection the recipient provides and use contractual or other safeguards so that your data is protected to a comparable standard. Where the GDPR applies and the destination does not benefit from an adequacy decision, we rely on Standard Contractual Clauses where possible or, for data that must be sent to perform your flight, on the transfer being necessary for the performance of our contract with you (GDPR Art. 49(1)(b)). You may ask our Privacy Officer for more information on the safeguards we use.

 

6. How long we keep your data

•  Quote requests that do not result in a booking: up to 24 months after our last contact.

•  Booking, invoicing and accounting records: [7] years, or longer where required by applicable tax, accounting and corporate law.

•  Passenger manifests, flight and operational records: for the periods required by applicable aviation regulations.

•  Marketing preferences: until you withdraw your consent or unsubscribe, plus a short suppression record so we do not contact you again.

 

We may keep data for longer where needed to establish, exercise or defend a legal claim.

 

7. How we protect your data

We use appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access, including encrypted connections (HTTPS), access controls and confidentiality obligations for our staff and partners. If a breach of security is likely to adversely affect you, we will notify you and the Privacy Commissioner for Bermuda without undue delay, as PIPA requires. No transmission over the internet is completely secure, so please avoid sending passport scans or sensitive information by unencrypted email unless we ask you to.

 

8. Your rights

Under PIPA you have the right to:

•  access the personal information we hold about you, and be told how it has been used and to whom it has been disclosed;

•  ask us to correct any error or omission in your personal information;

•  ask us to block, erase or destroy your personal information where it is no longer needed or is being used in breach of PIPA;

•  object at any time to our use of your personal information for direct marketing;

•  withdraw your consent at any time, without affecting use already made.

 

If the GDPR applies to you, you also have the rights to restrict processing, to object to processing based on our legitimate interests, and to receive your data in a portable format.

 

To exercise these rights, contact our Privacy Officer at [privacy email] or info@alaryjet.com. We may ask you to verify your identity. We will respond within 45 days, as PIPA requires, which may be extended by up to 30 days in the circumstances PIPA allows; where the GDPR applies, we will respond within one month.

 

If you are not satisfied with our response, you may complain to the Privacy Commissioner for Bermuda (PrivCom, www.privacy.bm). If you live or work in the European Economic Area or the United Kingdom, you may also complain to the data protection authority in your country.

 

9. Cookies and similar technologies

Our Website is hosted on Wix, which uses essential cookies to deliver the site securely, and may use analytics or other cookies only with your consent through the cookie banner. The quote search uses your browser's local storage to carry your trip details to the quote page. The Website also loads fonts and airport data from third-party content networks (Google Fonts and jsDelivr), which receive your IP address in order to deliver those files. You can change your cookie choices at any time through the cookie banner or your browser settings.

 

10. Children

Our services are booked by adults. Where children travel with us, their data is provided by a parent, guardian or the booker and used only to arrange and operate the flight. For children under the age of 14, we rely on the consent of a parent or guardian, as PIPA requires.

 

11. Changes to this Policy

We may update this Policy from time to time. The latest version will always be published on this page with its "Last updated" date. Where changes are significant, we will tell you by email or through the Website.