Privacy Policy For Private Jet Services

PJS Privacy Policy, Last Updated on 3/29/2022

WHO WE ARE

Our position at Private Jet Services is one of confidentiality, safety, and trust. A fundamental part of earning that trust means being clear about how we use your information and protecting your right to privacy.

WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT

We collect personal information about you when you use the PJS Platform. Without it, we may not be able to provide all services requested. This information includes:

• Contact Information, Account Information, and Profile Information including your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
  
  
• Identity Verification and Payment Information including images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information. ​​If you are not a PJS user, we may receive payment information relating to you, such as when a PJS user provides your payment card to complete a booking. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity.

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as aircraft or travel preferences
  
  
• Other Information. Such as when you fill in a form, add information to your account, post comments, communicate with our operations team. This may include health information if you choose to share it with us.

When you use the PJS Platform and Payment Services, we automatically collect personal information. This information may include:

• Usage Information. Such as the pages or content you view, searches for empty legs, bookings you have made, and other actions on the PJS Platform.
  
  
• Log Data and Device Information. Such as details about how you’ve used the PJS Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the PJS Platform. We may collect this information even if you haven’t created a PJS account or logged in.
  
  
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address, and other related transaction details.

When you download and use any of our mobile apps, we collect certain technical information from your device to enable the app to work properly and as otherwise described in this Privacy Statement. That technical information includes:

• Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module (“SIM”) operator, and SIM country
  
  
• Operating system and version
  
  
• Device model
  
  
• Performance and data usage
  
  
• Usage data, such as dates and times the app accesses our servers, the features and links clicked in the app, searches, transactions, and the data and files downloaded to the app
  
  
• Mobile device settings
  
  
• Other technical information such as app name, type, and version as needed to provide you with services
  
  

HOW WE USE INFORMATION WE COLLECT

Provide, Improve, and Develop the PJS Platform. Such as to:

• enable you to access the PJS Platform and make and receive payments,
  
• process your request,
• perform analytics, debug and conduct research,
• provide customer service, training
• send you messages, updates, security alerts, and account notifications,
• personalize and customize your experience based on your interactions with the PJS Platform, your search and booking history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products.

Create and Maintain a Trusted and Safer Environment. Including to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• enforce our agreements with third parties,
• Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process

Provide Payment services. Personal information is used to enable, or authorize third parties to use, Payment Services such as to:

• detect and prevent money laundering, fraud, abuse, and security incidents,
• conduct security investigations and risk assessments,
• comply with legal obligations (such as anti-money laundering regulations),
• enforce the Payment Terms and other payment policies,
• with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences, and,
• provide and improve Payment Services.

SHARING & DISCLOSURE

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

We share your personal information within Elevate Holdings companies, such as PJS and Keystone Aviation. Elevate Holdings companies share, access and use your personal information as described in this Privacy Statement.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: 

• comply with our legal obligations,
• comply with a valid legal request (such as a subpoena or court order) or to respond to claims asserted against PJS, 
• respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, 
• or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability.

Where appropriate, we may notify Members about legal requests unless: 

• providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or 
• we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to PJS, our Members, or expose PJS to a claim of obstruction of justice.

In jurisdictions where PJS facilitates or requires a registration, notification, permit, or license application or number of an owned aircraft, with a governmental authority, we may share information of participating owned aircraft with the relevant authority, both during the application process, when the Trip is published, and periodically thereafter, such as the owners full name and contact details, Accommodation address, tax identification number, registration, permit, or license number, trip details, reservation information, and trip information subject to applicable laws.

We share personal information with third-parties in connection with the delivery of services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party).

BUSINESS TRANSFERS

If PJS undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

CORPORATE AFFILIATES

To support us in providing, integrating, promoting and improving the PJS Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are Elevate Holdings and Keystone Aviation.

YOUR RIGHTS

You have certain rights and choices with respect to your personal information, as described below:

• If you have an account with us, you may change your communication preferences by either (1) logging in and updating the information in your account or (2) contacting us here
  
  
• You can update the accuracy of your information at any time by either logging into your account or contacting us
  
  
• If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. You can also log into your account to change communication settings or contact us here. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe
  
  
• For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and of your operating system
  
  
• If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent

Learn more about rights under GDPR here.

If your country of residence is China, learn more about your rights here.

If your state of residence is California, learn more about your rights here.

DATA ACCESS AND PORTABILITY

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

DATA ERASURE

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a PJS Account for fraud or safety reasons, we may retain information from that PJS Account to prevent that Member from opening a new PJS Account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Elevate Holdings and PJS Payments may keep information for tax, legal reporting, and auditing obligations.

Some copies of your information (e.g., movement messages, log records) will remain in our database, but are disassociated from personal identifiers.

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the PJS Platform will be subject to the revised Privacy Policy.

CONTACT INFORMATION AND RESPONSIBLE PJS ENTITIES

For questions or complaints about this Privacy Policy or PJS’s handling of personal information, please use our Contact Us form here.