This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You with regard to (i) the services We provide at the Service and (ii) Our promotional and marketing campaigns.
We use Your Personal Data to provide and improve the Service.
We are the data controller responsible for Your Personal Data
You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner (OIDPC), the Maltese supervisory authority for data protection issues (https://idpc.org.mt). We would, however, appreciate the chance to deal with your concerns before you approach the OIDPC so please contact us in the first instance. So that we're clear and there's no misunderstanding about how we handle your personal data, we will:
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or in
plural.
Definitions
For the purposes of this Privacy Policy:
We process Your Personal Data as follows:
| Purpose of Processing | Personal Data Subjects: Categories of Personal Data | Legal Basis |
|---|---|---|
| to perform Your orders | Our Website visitors, and Service users: phone number, location data, order data (flight date, flight time, number of passengers, luggage, flight price, jet type), payment details (cardholder name, expiration date, card number) | processing is necessary in order to take action on Your request prior to making a contract or the processing is necessary for the performance of Our contract with You. We shall not be able to provide You with Our services if You fail to provide the Personal Data |
| to create and manage an Account for You | Our Service users: phone number | |
| to provide You with the opportunity to edit Your account | Our Service users: name, surname, email- address, photo (avatar), balance | processing is necessary for the performance of a contract to which You are a party. We shall not be able to provide You with Our services if You fail to provide the Personal Data |
| to provide the passengers, You have added, with Our services | Passenger’s name, surname, date of birth, document details (type, serial number, date of issue/expiry, issuing country), flight details (flight date/time/price, luggage, jet type, food preferences) | |
| to contact and support You with a request received from You | Our Website visitors and services users: Name, phone number, email- address, troubleshooting and support data (content of a message including files attached) | Our legitimate interests to improve the quality of Our services |
| to keep You up to date on the latest service announcements, software updates, upgrades, system enhancements, special offers, and other information | Our Service users: phone number, email address, device information |
processing is necessary for the performance of a contract to which You are a party. We shall not
be able to provide You with Our Service if You fail to provide the Personal Data
OR Your consent when subscribing to our mailing list or accepting to receive push notifications. |
| to carry out corporate acquisitions, mergers or transactions | Our Website visitors and Service users: Name, phone number, email address, payment details depending on what would be divulged in each separate situation. | Our legitimate interests (to facilitate corporate acquisitions, mergers, or transactions) |
| to send You direct email marketing communications about Our services | Our Website visitors and Service users: name, email address |
Your consent to receive our newsletter. You may withdraw Your consent at any time by clicking
the “unsubscribe” link in the email communications We send You
Or Our legitimate interests where We may send You marketing communications without Your consent |
| to better understand Your preferences, to help You to navigate the Website, to personalize and provide a more convenient experience to You, to analyze which pages You visit, and to measure advertising and promotional effectiveness | Our Website visitors: IP- address, location (country or town), OS type and version, browser type and version, type of device and its display resolution, traffic source for the visitor, OS and browser language, which buttons are pressed /pages are opened | Your consent to store Cookies in Your browser. You may withdraw Your consent at any time by changing the settings of Your web browser. |
By providing Us with or allowing Us to access Personal Data relating to individuals other than Yourself, You are letting Us know that You have the authority to send Us that Personal Data or the authority to permit Us to access those data in the manner described in this Privacy Policy.
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. The criteria We use to determine what is ‘necessary’ depends on the particular Personal Data in question and the specific relationship We have with You (including its duration). We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies or where We otherwise have a right to do so, such as to defend Ourselves against legal claims.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
The Company will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data and other personal information.
We may use third-party Service Providers to provide better improvement of our Service. We have partnered with a number of authorized Service Providers, whose services and solutions complement, facilitate and enhance Our own guarantees under written data processing agreements to ensure that the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679) implemented into Maltese law by virtue of the Data Protection Act (Chapter 586 of the Laws of Malta) will be met and the rights of Personal Data subjects are protected.
Should we transfer Your Personal Data to third countries in the absence of any adequacy decisions regarding such countries, we will make use of any applicable derogations as found under the laws in the preceding paragraph, and where required, implement any and all relevant safeguards, including the EU Standard Contractual Clauses.
We may share Your Personal Data with the following Service Providers:
| Data Recipients, their Location and the Link to Privacy Policy / Website if applicable | Data Recipients, their Location and the Link to Privacy Policy / Website if applicable Purpose of Transfer |
|---|---|
| Affiliated companies (Cyprus, Kazakhstan, Malta, the UK) | Service Providers |
| Airlines | Transportation Service Provider |
| DigitalOcean, LLC (the USA), Privacy Policy | Hosting Provider |
| Ecommpay Limited (the UK), Privacy Policy | Payment Service Provider |
| Mixpanel, Inc. (the USA), Privacy Policy | Product Analytics Service Provider |
| Twilio Inc. (the USA), Privacy Policy | Messaging Service Provider |
| Google LLC (the USA), Privacy Policy | Web Analytics Service Provider (Google Analytics, Google Tag Manager) |
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We
will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy
Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so
by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
We do not make any automated decisions about You that would result in legal or other similarly significant effects on You.
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Our Website, like many others, uses small files called cookies to help it function properly and offer you a fun, customised experience.
If you haven’t already read our Privacy Policy, we just want to reiterate, that We are required to obtain your consent for certain cookies.
We hope that this cookie policy will help you better understand what types of cookies we use and why we use them.
The Cookies active on Our Website can be the categories as follows:
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. We do not require Your consent to place this type of cookies on Your Device.
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
We are very sorry to bother you with a cookie banner when you access the Website, but We need to inform You of the existence of Our cookie policy and obtain Your consent (where applicable).
If You choose to accept and consent to certain Cookies, Your browser will remember this for the next time.
You may choose to withdraw consent at any time. You will need to do this by changing some of Your browser settings.
You may see the cookie management instructions published by the browsers vendors at Google Chrome, Safari ( Desktop, Mobile), Firefox, Internet Explorer respectively.
You have rights under data protection laws in relation to Your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to Your Personal Data (commonly known as a "data subject access request"). This enables You to receive a copy of the Personal Data We hold about You. If You require this, then please reach out to Our support team via the Contact Us page.
Request erasure of your Personal Data. This enables You to ask Us to delete or remove Personal Data where there is no good reason for Us continuing to process it. This includes where You have successfully exercised Your right to object to processing (see below), where We may have processed Your information unlawfully or where We are required to erase Your Personal Data to comply with local law. Note, however, that We may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
Object to processing of Your Personal Data. This is in situations where We are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms. You may also have the right to object where We are processing Your Personal Data for direct marketing purposes (and where We are not relying on Your consent to do so). In some cases, We may demonstrate that we have compelling legitimate grounds to process Your information which override Your right to object.
Request restriction of processing of Your Personal Data. This enables You to ask us to suspend the processing of Your Personal Data in the following scenarios: (a) where Our use of the Personal Data is unlawful but You do not want us to erase it; (b) where You need us to hold the Personal Data even if we no longer require it as You need it to establish, exercise or defend legal claims; or (c) You have objected to Our use of Your Personal Data but We need to verify whether We have overriding legitimate grounds to use it.
Request the transfer of Your Personal Data to you or to a third party. We will provide to You Your Personal Data in a structured, commonly used, machine-readable format, which You can then transfer to an applicable third party. Alternatively, We can transfer Your Personal Data directly to the third party if You so prefer and if technically feasible. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw consent at any time where We are relying on consent to process Your Personal Data. However, this will not affect the lawfulness of any processing carried out before You withdraw your consent. If you withdraw your consent, we will not be able to provide the related Services to You and You will be informed of this at the time of withdrawal of consent.
If You wish to exercise any of the above rights then please reach out to Our support team via the Contact us page.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from You to help Us confirm your identity and ensure Your right
to access your Personal Data (or to exercise any of Your other rights). This is a security measure to ensure
that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to
ask You for further information in relation to Your request to speed up Our response.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email if You provided Us with Your email address and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, You can contact us: