Privacy Policy

Privát Aviation Holdings (“Privát”) respects your right to privacy and is committed to protecting our customers’ personal information (also called for the purposes of this Privacy Policy "personal data"). This Privacy Policy summarizes our practices regarding information collection, use and disclosure practices for this Website (http://flyprivat.com).

WHAT PERSONAL INFORMATION DO WE GATHER?

We process personal data in accordance with the applicable laws and, to the extent applicable, with the European General Data Protection Regulation (GDPR). Personal data that we process may also be subject to contractual or professional confidentiality obligations applicable to us.

We process personal data for the following purposes (hereinafter the "Purposes") and legal bases:

(a) As required by the Transportation Security Administration
The Transportation Security Administration (TSA) requires you to provide your full name, date of birth, and gender for the purpose of watch list screening, under the authority of 49 U.S.C. section 114, the Intelligence Reform and Terrorism Prevention Act of 2004 and 49 C.F.R parts 1540 and 1560. You may also provide your Redress Number, if available. Failure to provide your full name, date of birth, and gender may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. For more on TSA privacy policies, or to review the system of records notice and the privacy impact assessment, please see the TSA Web site at
www.tsa.gov.

(b) For the performance of contractual obligations

We collect and process personal data as necessary for the performance of a contract to which you or a related person is a party, or to carry out pre-contractual measures that occur as part of a request.

(c) For compliance with a legal obligation or in the public interest

We may be subject to various legal obligations which require us to process and collect personal data, including in relation to the provision of information about products and services, the recording of phone conversations, the satisfaction of any requirements of cooperation with, or reporting to, any competent public prosecution,supervisory, administrative or tax authority or court, as well as the assessment and management of risks.

(d) For the purposes of safeguarding legitimate interests

When necessary, we process your personal data for the purpose of the legitimate interests pursued by us or a third party, if such processing does not unduly affect your interest or fundamental rights and freedoms. Examples include the development of our business relationship with you, the market studies and advertising, unless you have objected to the use of your data for marketing, the recording of phone conversations to verify instructions, improve the quality of our services or to

safeguard our rights, the exercise or defense of actual or potential legal claims, or the conduct of investigations or similar proceedings, review and improvement of our internal processes and organization, the evaluation of certain characteristics of data subject on the basis of automatic processing of personal data (e.g. analytical tools).

(e) On the basis of your consent

To the extent that the processing of your personal data requires that you give your prior consent thereto, we will ask for your consent in due time. Any consent granted may be revoked at any time. Please be advised that the revocation of your consent shall only have effect for the future. Any processing that was carried out prior to the revocation shall not be affected thereby.

The provision of personal data may be mandatory, for instance in connection with compliance with applicable laws and regulations. If the required data are not provided, this may preclude us from establishing or pursuing a business relationship or from rendering services to you.

When you visit this Website, you may provide Privát with two types of information: personal data you knowingly and voluntarily choose to disclose, and personal data that we automatically collect as you browse this Website

.

Information You Voluntarily Submit. –  We collect and store any information you enter on this Website, or provide to Privát in other contacts we have with you. Information is collected from visitors to this Website, including in the areas described below, as applicable. You may change any of your personally identifiable information in your account online at any time. You may request to have the information on your account deleted or removed, although you cannot delete information associated with past purchases.

Website Registration –  We collect IP addresses for the purposes of system administration, to gather broad demographic information, to potentially enable ads to be served on this Website, to report non-personally identifiable information to our advertisers, and to monitor the level of activity on this Website. We collect information from visitors to this Website regarding the URLs they visited, their IP addresses, domain types, the browser type used to come to this Website, the country, state and telephone area code where their servers are located, the pages of this Website that visitors viewed during their visit, the duration of their visit, and any search terms entered on this Website.

Employment Applications – The Careers section of this Website may allow you to submit information related to job opportunities with Privát. Please note that your submission of such information may be further governed by specific provisions that appear on any applicable employment opportunities sections of this Website.

Online Surveys – In order to improve our services to you, we ask some of our customers to voluntarily complete surveys, which may be collected by an independent third party. Individual survey answers are confidential, although non-personally identifiable information is collected and disclosed to third parties. If you do not wish to participate in a survey, simply decline to participate when asked.

Contests and Sweepstakes – When you enter a contest or other promotion, we may ask you for contact information such as your name, birthday, phone number, mailing address and email address in order to administer the contest, to send you promotional emails, notify winners and make the winners’ list publicly available pursuant to certain states’ laws. Your consent to such promotional use and disclosure of this information is a condition of your participation. As a condition of receiving any prize, you will be required to submit an eligibility affidavit, for Privát to ensure that you are eligible to receive the prize according to the contest rules.

Contact Information – If you contact Privát by telephone, e-mail, social websites, or letter, or you submit this information via our newsletter signup page, quote request page or other page on this Website, we may keep a record of your correspondence, comments and/or any contact and/or trip information you provide. If you report a problem with this Website, we may collect such information in a file specific to you. If you contact Privát through our feedback area or by calling one of our customer service representatives, we may ask for your name, phone number and email address in order to send you a reply. If other users or third parties send Privát correspondence about your activities on this Website, we may keep the information in a file specific to you. In the event we use a third party to help us provide customer service, we will provide them with your contact information.

Advertising – We may display advertisements on this Website in the form of targeted banners and promotions. Privát takes the advertisement and includes it in a Privát email to prior customers meeting certain criteria. We may also display ads linked to certain search terms that you have entered, or to certain pages that you are viewing. In this process, advertisers never have access to individual account information; only Privát has access to individual’s accounts. Additionally, Privát may share aggregated data with advertisers.

Newsletters and Emails – We offer free newsletters and promotional emails as a service to our customers. We will send you newsletters and emails periodically listing current specials and deals. To stop receiving our newsletter, send an email to us at [optout@flyprivat.com] [b]or follow the opt-out procedures set forth in such newsletters or emails.

Information Collected and Stored Automatically – When you browse this Website, you and your Web browser may also transmit information that we automatically collect. We do log your IP address (the Internet address of your computer), the Web pages you visit and the time of your visit, and other click-stream data. This information may be combined with other personal information you have provided. The only other type of information automatically provided to Privát is the type of computer, operating system and browser you are using. This information is provided by your browser, which we use to improve the performance of this Website and make it more compatible with the technology used by the visitors of this Website. We may also place small data files, called “cookies,” in the browser file of your computer’s hard drive. These cookies automatically identify your browser to our server whenever you interact with this Website. We use the cookies to record Website statistics. Most browsers automatically accept the cookies, but you usually can change your browser setting to prevent the acceptance of cookies. Certain Web pages will not function properly if you choose not to accept cookies.

HOW DO WE USE YOUR PERSONAL INFORMATION

We use your personal information to communicate with you if and when necessary in connection with your use of this Website, to respond to your questions, or to send you material and information you request. We may also use your personal information to: Personalize your Website experience and to allow Privát to deliver the type of content and product information in which you are most interested; Consider your suggestions; Possibly respond directly to you for clarification of questions raised; Process your request for

materials or information; Try to answer any questions you may have; Book a trip for you; Register you for an event, contest or sweepstakes, if you request it; Provide you with email messages and other information regarding upcoming events, new services and general information about our products and services and those of our select business partners. You may elect not to receive these communications, either when you initially register at this Website, or at any time thereafter. See the section of this Privacy Statement below titled “CHOICE/OPT OUT”.

We may also use collected information in order to help diagnose problems with this Website. We may use all information we collect to analyze statistical use patterns and demographic data (basically, where our visitors come from and what demographic characteristics they have) and to improve this Website to better serve our customers. We use your IP address to help diagnose problems with our servers, and to administer this Website. Your IP address is used to help identify you and to gather broad demographic information. We may also prepare and keep statistical records and other data about you and other users of this Website, but we do that in a way that does not identify you or any other user personally. We may hire third parties to help Privát collect and analyze such data, and we may share such statistical data with third parties. Again, such statistical data will not specifically identify you or any other user. We use this information to help us make this Website more useful to visitors -- to learn about the number of visitors to this Website, what part of this Website they are interested in, how long they use this Website, and the

types of technology our visitors use.

DISCLOSING YOUR PERSONAL INFORMATION TO OTHERS

The personally identifiable information collected by Privát is used only for the limited purposes described in this Privacy Policy, including processing inquiries for products and services, for statistical purposes, for improving this Website and its performance, and to notify you of products or special offers that may be of interest to you. We will need to disclose your personally identifiable information to third parties to provide customers and deliver promotional emails to you from Privát. In connection with these transactions, we collect data necessary to complete the transaction that is furnished by you. This information may be furnished to a third party in order to facilitate the transaction. We may disclose your information to our affiliates or service providers who assist Privát in operating this Website or conducting our business, including but not limited to Jet-A. LLC. We may also share such information among our subsidiaries and affiliates as necessary to provide you with the information and services you request or in which you may otherwise be interested. We may disclose information about you if and when we believe it is necessary to comply with any law, rule, court order, or subpoena, or to enforce our legal rights or the rules of this Website, or to protect our business, property and operations, or in connection with a sale, acquisition, merger or other business combination of our business with a third party. We may also disclose non-personally identifiable visitor information to other parties for marketing, advertising or other uses. Except in the limited circumstances stated in this section, we do not sell, rent, license, trade or otherwise disclose the personal information of visitors to this Website to unaffiliated third parties.

LINKS TO OTHER SITES

We may create links to other Websites that we think may be of interest to you. We do not endorse any other Websites, and this Privacy Policy applies only to your use of this Website. We have not reviewed the privacy policies of any Websites we link to this Website, and you should read the privacy policies of each Website you visit to determine what information about you that Website may collect and use.

SECURITY

Because we are committed to your privacy, we have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security, and correctly use the personal information we collect online. When you access your personal information on this Website, we offer the use of a secure server. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to Privát or from us, and you do so at your own risk.

DATA RETENTION

As a matter of principle, we process and store your personal data as long as it is necessary in order to achieve the Purposes. We will delete or redact your personal data regularly once they are no longer necessary in order to achieve the Purposes, unless a further processing of your personal data is necessary for the following purposes: (i) compliance with longer records retention periods under applicable law or regulations and (ii) preservation of all forms of relevant information to exercise or defend actual or potential legal claims or to conduct investigations or similar proceedings.

CUSTOMER RIGHTS ON THEIR PERSONAL DATA

Subject to any applicable restrictions or requirements, you have the right to (i) request access to, and receive copy of, your personal data, (ii) request rectification of your personal data if they are inaccurate, (iii) request erasure of your personal data when the processing is not or no longer necessary for the Purposes, subject to applicable retention records, (iv) request a restriction of the processing of your personal data subject to the restrictions, (v) object to the processing of your personal data, in which case we will no longer process your personal data unless we have compelling legitimate grounds to do so and if applicable, (vi) receive your personal data in structured, commonly used and machine readable format (data portability). You may exercise these rights by submitting a request to the following address: [privacy@flyprivat.com][c]. In addition, you have the right to be informed about the personal data stored and the purpose of the processing at any time. You may also lodge a complaint with the competent data protection supervisory authority if you believe that our processing of your personal data infringes applicable data protection laws.

CHANGES IN OUR PRIVACY POLICY

By using this Website, you consent to our collection and the use of your personal information as described in this Privacy Policy. If we change our Privacy Policy, we will post these changes on this Website. You have the opportunity to review this Privacy Policy each time you use this Website so that you are aware of any modifications made to these policies. We may also notify you of any change in the manner deemed most appropriate.

CHOICE/OPT OUT

This Website provides users the opportunity to opt-out of receiving communications from Privát at the point where we request information about the visitor. You have the option to no longer receive communication from us. If you request your account information be deleted from our database, we may maintain information about individual sales transactions for the purpose of recordkeeping and servicing. You can send your request via email to [optout@flyprivat.com][d], or by mail to the following postal address:

Privát Aviation Holdings

8690 Aero Dr.

Suite 115

San Diego, CA  92123

Please note that due to email production schedules, you may receive an emall message from Privát after you have provided your opt-out notice.

QUESTIONS ABOUT OUR PRIVACY POLICY

If you have questions about this Website or Privát’s Privacy Policy, please feel free to contact us at [privacy@flyprivat.com][e]. This Privacy Policy is not a contract and does not create any legal rights or obligations.