Privacy Notice

1Controller of the information

Phoenix Private Flights acts as a commercial intermediary and broker for private flights and services related to business aviation.

For any inquiry related to privacy or the processing of personal data, you may contact us using the details above.

2Information we may collect

Depending on how a user interacts with Phoenix Private Flights, we may collect the following categories of information:

Contact information

First and last name, email address, telephone number and other contact details voluntarily provided.

Travel-related information

Origin, destination, travel dates, schedules, number of passengers, type of trip, stops, aircraft preferences, special requirements, baggage, catering, ground transportation and any other information needed to prepare or coordinate a flight.

Passenger information

When necessary to make a booking or satisfy operational or legal requirements, we may request full name, date of birth, nationality, sex where applicable, passport or identity-document number and copy, and any other information required by air operators or immigration, customs, airport or security authorities.

When a person provides information relating to other passengers, that person represents that they are authorized to provide it for the management of the requested trip.

Commercial and transactional information

We may collect information related to quotes, bookings, contracts, invoicing, payments, purchased services, flight history, commercial communications and the client relationship.

Phoenix Private Flights may use third-party payment processors. We do not necessarily store directly all credit- or debit-card details used by those providers.

Communications

We may retain emails, messages, quote requests, telephone communications, WhatsApp messages or other communications with our clients, passengers, suppliers or operators where necessary to provide the service or maintain business records.

Technical information

When you visit our website, we may automatically receive certain technical information such as IP address, device type, browser, operating system, language, pages visited, access date and time, referring website and other technical or security data.

3How we use information

We may use personal information to:

• respond to inquiries and quote requests;
• locate and compare available aircraft and operators;
• prepare commercial proposals;
• manage, book and coordinate flights;
• verify passenger details;
• transmit necessary information to air operators and suppliers;
• coordinate FBO, handling, catering, ground transportation and other related services;
• meet immigration, customs, airport or security requirements;
• process and administer payments;
• issue invoices and commercial documentation;
• provide assistance before, during and after a flight;
• maintain communication with clients;
• prevent fraud, abuse or illegal activities;
• maintain the security of our systems;
• manage claims or disputes;
• comply with legal, regulatory, tax or judicial obligations;
• improve our services and user experience;
• conduct internal analysis and measure website performance;
• send marketing communications where permitted by applicable law.

Where required by applicable law, we will use information on the basis of the data subject’s consent, performance of a contract or pre-contractual measures, compliance with legal obligations, our legitimate business interests or another legally permitted basis.

4Information needed to quote and operate a flight

An initial quote request will normally require only basic trip information and contact details.

More sensitive information, such as passports, identity documents or additional passenger details, will be requested only when reasonably necessary to proceed with a booking, coordinate a flight, or comply with requirements imposed by an operator or competent authority.

We recommend that you do not send sensitive personal documents until Phoenix Private Flights requests them or they become necessary for an operation.

5With whom we may share information

Phoenix Private Flights is a private-flight broker and intermediary. To provide the requested services, it may be necessary to disclose certain information to independent third parties.

Where appropriate, we may share information with:

air operators, aircraft owners or managers, charter companies, crews, FBOs, airports, handling companies, catering providers, ground transportation companies, travel-service providers, payment processors, technology platforms, communications services, legal and accounting advisers, IT infrastructure providers and government authorities.

Information shared will be reasonably limited to what is necessary to provide the service, process the operation or comply with a legal obligation.

Air operators and other independent suppliers may act as independent controllers of certain data and may be subject to their own privacy policies.

6International transfers

Because private aviation is international in nature, passenger and client information may be transmitted, stored or processed in countries other than the data subject’s country of residence.

For example, an international flight may require certain information to be disclosed to an air operator, airport, FBO, immigration authority or supplier located in another country.

Where required by applicable law, we will take reasonable measures intended to protect information during those transfers.

7Cookies and similar technologies

Phoenix Private Flights may use cookies and similar technologies that are necessary for the operation, security, performance and improvement of the website.

We may also use measurement or analytics tools to understand how users interact with our site.

If we use advertising, remarketing or tracking technologies that require consent or additional choices under applicable law, we will provide the corresponding mechanisms.

Users may also control certain cookies through their browser settings.

8Marketing communications

We may use the contact details of clients or interested persons to send information about our services, flight availability, empty legs, news or commercial proposals where legally permitted.

Recipients may request to stop receiving promotional communications at any time by using the instructions included in the communication or by writing to:

sales@phoenixprivateflights.com

Communications strictly related to a quote, booking, payment, flight or contractual relationship may continue to be sent when necessary to provide the service.

9Sale and commercial use of personal information

Phoenix Private Flights does not sell client or passenger personal information to third parties in exchange for money.

Disclosure of information to air operators, suppliers, processors or authorities as needed to arrange and perform a service does not constitute a commercial sale of databases by Phoenix Private Flights.

If future advertising technologies used on the site are considered a “sale” or “sharing” of personal information under applicable privacy law, Phoenix Private Flights will implement the notices and opt-out mechanisms required by that law.

10Data retention

We will retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to meet legal, tax, accounting, contractual, regulatory, security or dispute-resolution obligations.

Retention periods may vary according to the nature of the information and the relationship with the data subject.

When information is no longer necessary, we may delete it, anonymize it or retain it only where there is an obligation or legitimate basis to do so.

Whenever reasonably possible, we will seek not to retain copies of sensitive personal documents for longer than necessary for the relevant operation.

11Security

Phoenix Private Flights adopts reasonable administrative, technical and organizational measures intended to protect information against loss, unauthorized access, misuse, alteration or disclosure.

However, no electronic system, Internet transmission, cloud storage or communications service can guarantee absolute security.

For this reason, users should avoid sending highly sensitive documentation through unsolicited or insecure channels.

12Privacy rights

Depending on the country or state in which the data subject is located and the applicable law, that person may have the right to:

• access certain personal data we hold about them;
• request correction of inaccurate information;
• request deletion of certain data;
• object to or request restriction of certain processing;
• withdraw previously given consent;
• request data portability where applicable;
• obtain information about certain categories of third parties to whom data has been disclosed;
• exercise rights relating to the sale, sharing or use of certain information where applicable law so provides.

To exercise a privacy right, you may write to:

sales@phoenixprivateflights.com

We may request information reasonably necessary to verify the requester’s identity and protect information against fraudulent requests.

We will not unlawfully discriminate against a person for exercising privacy rights recognized by applicable law.

13California residents

Where the California Consumer Privacy Act, as amended and under its current regulations, applies to Phoenix Private Flights and the relevant data subject, California residents may have additional rights relating to knowledge, access, correction, deletion and certain forms of use, sale or sharing of personal information.

The categories of information we may collect are described in section 2 of this Notice, and the corresponding purposes are described primarily in section 3.

Phoenix Private Flights does not sell personal information in exchange for money.

Where there is a legal obligation to provide a specific option to limit or opt out of a particular sale or sharing of data, Phoenix Private Flights will make the mechanism required by applicable law available to the user.

14Users in the European Economic Area, United Kingdom and other jurisdictions

Where the European Union General Data Protection Regulation, the UK GDPR or equivalent legislation applies, Phoenix Private Flights will process information using a valid legal basis.

Depending on the circumstances, that basis may consist of:

• performance of a contract or steps requested before entering into a contract;
• compliance with legal obligations;
• legitimate interests of Phoenix Private Flights or third parties that are not overridden by the fundamental rights of the data subject;
• consent, where required.

Data subjects may exercise the rights granted to them by applicable law and, where appropriate, lodge a complaint with the competent data-protection authority.

15Minors

Our services are not directed to minors seeking to book flights on their own behalf.

Minors may, however, travel as passengers. In those cases, we may process the necessary information about the minor when it is provided by parents, guardians, persons responsible for the trip or other authorized persons, solely to arrange transportation and meet legal or operational requirements.

We do not intentionally use information about minors for targeted behavioral advertising.

16Information provided by third parties

We may receive passenger or client information through personal assistants, companies, travel advisers, travel agencies, brokers, family members, representatives, coordinators or other persons arranging a trip.

Anyone who provides us with another person’s personal data must have sufficient authority to do so and must ensure that the person can be made aware of this Privacy Notice where necessary.

17Third-party links and services

Our website may include links to or integrations with third-party services.

Phoenix Private Flights does not control the privacy policies or practices of independent sites or services and recommends reviewing their respective privacy notices.

18Legal requirements and protection of rights

We may retain, use or disclose information where we reasonably believe this is necessary to:

• comply with a law, regulation, court order or valid request from an authority;
• protect the safety of passengers or other persons;
• investigate fraud or illegal activity;
• enforce our contracts;
• protect our legal rights, property or legitimate interests.

19Changes to this Notice

We may update this Privacy Notice as a result of legal, technological, operational or commercial changes.

The current version will be published on phoenixprivateflights.com together with the date of the latest update.

Where a change is material and applicable law requires additional notice, we will take the corresponding reasonable measures.

20Contact

For questions, requests or inquiries relating to this Privacy Notice or the processing of personal information: