Privacy Policy

Platinum Jets is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which we process Personal Data that we collect from you or that is provided to us about you.

1.     YOUR PERSONAL DATA

The Data Subject, Controller and Processor for Personal Data

For the purposes of the UK Data Protection Act 2018 and General Data Protection Regulation (GDPR) (be it as these regulations apply to the UK or to Europe), Platinum Jets will be either the “Data Processor” or “Data Controller” for any Personal Data provided to us.

If the Data Subject’s employer provides us with their Personal Data to enable us to provide products and services to the Data Subject or their employer, it is the Data Subject’s employer that is the Data Controller and under these circumstances, the Data Controller is the Client Company of Platinum Jets, and Platinum Jets in turn acts as the Processor of the Data Subject’s Personal Data.

Where we have been so authorised by the Data Controller by way of a contract for services, Platinum Jets, as Processor, will use the Personal Data of the Data Subject, provided by the Client Company, to facilitate flight charter booking and other travel related arrangements for the Data Subject.

It is performance of this contract with the Client Company which forms the ‘Legal Basis’ for the processing of Personal Data carried out by Platinum Jets. (Further information on ‘Legal Basis’ is set out in the appendix to this document.)

There are circumstances where Platinum Jets may also be the Data Controller.

If the Data Subject provides us with their Personal Data directly, or if Platinum Jets collects additional Personal Data directly from a Data Subject, Platinum Jets will be acting under a ‘Legitimate Interest’ to legally process the Personal Data to facilitate flight charter bookings and other travel related arrangements for the Data Subject and to fulfil the contractual requirements to a Client Company.

In circumstances where Platinum Jets collects Personal Data from the Data Subject, Platinum Jets will obtain that Data Subject’s express consent, unless Platinum Jets has a Legitimate Interest, or Legal Obligation to process that Personal Data as outlined in this Privacy Policy.

When we talk about Data Subjects and Personal Data in this Privacy Policy, we mean Personal Data which may identify you or which could be used to identify you, for example, your name and contact details, your flight charter and other travel related arrangements.

In this Privacy Policy, references to the Data Subject as ‘you’ or ‘your’ means you if you have provided us with your Personal Data directly, or the Client Company (including its affiliates and its employees) if your Personal Data has been provided by the Client Company.

Reference in this notice to ‘our’, ‘us’ or ‘we’ means Platinum Jets.

2.     PERSONAL DATA WE COLLECT ABOUT YOU

The Personal Data we collect about you will only be Personal Data specifically required to fulfil flight charter bookings and other travel related arrangements. Such Personal Data may be collected directly from you or provided to Platinum Jets via your employer. Such Personal Data will only be processed for that purpose, or where we have a Legal Obligation to process that Personal Data, for example where we are required to process your Personal Data for the purposes of local health and sfatey regulations.

Certain kinds of Personal Data collected, such as data about your racial or ethnic origin, physical or mental health, or religious beliefs requires additional protection. By providing any sensitive data of this kind you agree that we may collect it and use it to provide our services or to comply with a legal obligation.

3.     HOW WE USE YOUR PERSONAL DATA

Platinum Jets has adopted the following principles to govern its processing and use of your Personal Data. Platinum Jets is committed to ensuring that the Personal Data collected:

  • Shall be processed lawfully, fairly, and in a transparent manner;
    • Is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is collected and/or processed;
    • Is retained only for as long as it is required to fulfil our contractual or legal requirements, or to provide statistics to our Client Company;
  • Is accurate and, where necessary, kept up to date; and
    • Will not be used by Platinum Jets for any monitoring or profiling activity or process and will not adopt any automated decision making processes.

4.     HOW WE PROTECT YOUR PERSONAL DATA

Platinum Jets protects your Personal Data against unauthorised access, unlawful use, accidental loss, corruption or destruction. We use technical measures to protect your Personal Data such as encryption and password protection. We also use operational measures to protect your Personal Data, for example by restricting access to only those in personnel who need to access your data.

We are mindful of technological developments associated with the protection of and risks to your Personal Data and as such we keep these security measures under review. Platinum Jets may therefore need to implement adequate alternative technical and organisational measures.

5.     DATA RETENTION

We only keep your Personal Data for as long it is necessary to fulfil the purposes for which it was collected.  This retention period may vary due to our legal or contractual obligations.   For example:

  • if you are the Client Company, or have an account with us, we will keep your Personal Data while your account is active for as long as it is needed to provide our services to you; or
  • we will keep your Personal Data for as long as we are required by law to keep health and safety records, or records of financial transactions.

6.     YOUR RIGHTS

As a Data Subject you have the rights set out in this section below:

Platinum Jets will always fully respect your rights regarding the processing of your Personal Data and has provided below at section 10 the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the relevant data protection laws.

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including 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 that we hold about you and to check that we are lawfully processing it.
  • request correction of your Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • 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. You also have the right to ask us to delete or remove your Personal Data 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 laws. Please 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 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 also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • request restriction of processing your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • request transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please 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 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 may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • If you wish to exercise any of the rights set out above, please contact us

Under certain circumstances, you have the right to withdraw your consent to our use of your Personal Data at any time. However,

Please note, if you do not provide us with your Personal Data, or if you withdraw your consent this may result in an inability by Platinum Jets to fulfil its contractual requirements to provide your flight charter and other travel related arrangements or the level of service we are able to provide may be negatively impacted.

For example, most flight charter and other travel related arrangements, must be made under the traveller’s full name and must include contact details and appropriate identification (e.g. passport details).

Platinum Jets cannot process any booking for a flight charter or other travel related arrangements without this Personal Data.

7.     SHARING YOUR DATA

Transfers to Third Parties

To fulfil your flight charter and any other travel related arrangements, it will in most cases be necessary for Platinum Jets to process Personal Data via a third party (these include but are not limited to flight charter operators, hotels, car hire companies, and in certain cases may include visa processing companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of the flight charter and any other travel related arrangements.

Sending data outside of the European Union

Platinum Jets will not transfer Personal Data to a country or territory outside the European Economic Area (EEA) or the UK unless the transfer is made to a country or territory recognised by the EU as having an adequate level of Data Security, unless the transfer is made with your consent, or is made to satisfy the legitimate interest of Platinum Jets in regard to its contractual arrangements with its clients, or Platinum Jets have put in place adequate safeguards to ensure your Personal Data is protected to the same standard as is expected from the UK and EU data protection regulations.

All internal group transfers of Personal Data shall be subject to written agreements under Platinum Jets’ Intra Group Data Transfer Agreement (IGDTA) for internal Data transfers which are based on Standard Contractual Clauses recognised by the European Data Protection Authority, or International Data Transfer Agreements (with or without an EU addendum) as required by the UK Information Commissioner’s Office.

8.     CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. Any changes we may make to our Privacy Policy in the future will be notified and made available to you using our website.

9.     COOKIES

Protecting our customers is at the heart of everything we do at Platinum Jets and protecting your Personal Data is no exception.

A Cookie is a small text file that can be stored by your browser on the device you use to access internet and allows the browser to pass small amounts of information to help you efficiently browse our website and how you interact with our webpages to improve your experience.

We use cookies on our website (www.platinumjets.co.uk) to help make your visits more effective, and we explain more about how and why we use them in our Cookies Policy.

We will never share any personal information about you with any third parties and the cookies used maintain your anonymity.

10.    COMPLAINTS

You have the right to make a complaint at any time to a relevant Data Protection Authority based within the UK or the relevant EEA Member State; for example, the UK regulator for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk).

11.    CONTACT US

To exercise any of your rights, you can send an email to us at vip@platinumjets.co.uk or you can write to us at: Data Protection Platinum Jets Limited, 10 John Street, London, WC1N 2EB.

Appendix – Definitions of certain terms referred to in this Privacy Policy

Personal Data: means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: means any operation or set of operations which is performed upon Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.

Data Controller: this means the person or company that determines the purposes and the means of processing Personal Data.

Data Processor: means a natural or legal person, public authority, agency or any other body which processes Personal Data on behalf of the controller.

Legal Basis for Processing: At least one of these must apply whenever Personal Data is processed:

  1. Consent: the individual has given clear consent for the processing of their Personal Data for a specific purpose.
  2. Contract: the processing is necessary for compliance with a contract.
  3. Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
  4. Vital interests: the processing is necessary to protect someone’s life.
  5. Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.6.     Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s Personal Data which overrides those legitimate interests.