Privacy Page

EFFECTIVE DATE: APRIL 2019

  1. THIS PRIVACY POLICY

All information described in this Privacy Policy is processed by 5 Skies Aviation, LLC (“5 Skies Aviation”, “we”, “us”, or “our”) as data controller. This Privacy Policy describes our practices related to the use, storage, and disclosure of personal information we collect from or about you when you interact with us in the course of our providing air travel services, ancillary services, or other services provided by us or by others acting on our behalf, including when you use our website www.5skiesaviation.com (“Website”) or our 5 Skies Aviation App (“App”). This Privacy Policy also describes our processing of the personal data of individuals representing our business customers and suppliers.

5 Skies Aviation reserves the right to modify this Privacy Policy at any time and without prior notice. We will post any changes to our Website. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

  1. HOW TO CONTACT US

If you have any questions or comments regarding this Privacy Policy, please contact our Data Protection Officer at charter@5skiesaviation.com or contact our Client Services department by telephone or mail.

  1. HOW DOES 5 SKIES AVIATION COLLECT AND RECEIVE YOUR INFORMATION?

3.1. We collect information from you

We may collect and receive information from you, including when you:

  • use or access our Website or App, such as when you complete the “passenger details” section during the course of a booking, even if you do not complete the booking, or you request information about our products and/or services;

register, create, or modify an online or in-app account with us, or our Promotional Partners, communicate with us by email, including when you email us at charter@5skiesaviation.com, telephone, in writing or social media;

  • Our Promotional Partnersinclude hotel, car rental, ground transportation, catering, vacation and other businesses with whom you may qualify for discounts or benefits and businesses with whom you may be offered a discount or benefit as a result of your transactions with 5 Skies Aviation.
  • use any of our services, including when you travel with us, use airports or fixed based operators where we operate, or use any facilities within these airports;
  • through cookies and other tracking technologies on our Website and App (see section 6below); and
  • are associated to a company we do business with

3.2. Automatic access and data collection from our App

Our App may access certain device information and/or components automatically.

3.3. We collect information from other sources

We may receive your personal information from other charter operators, other, airlines, and from brokers and travel agencies and your company in connection with your travel booking.

We may also receive your personal information from Promotional Partners in connection with your transactions with 5 Skies Aviation.

Our suppliers and other businesses we deal with provide us personal information of their representatives.

This Privacy Policy applies to information we receive from those other sources, as well as to information we collect from you or generate about you.

  1. HOW 5 SKIES AVIATION USES YOUR DATA

4.1. Information about you and how we use it

This section describes what personal information we collect about you, the purposes for which we use it, and for the purposes of the European Union General Data Protection Regulation, the legal basis pursuant to which we process the information. Please also see section 4.2 regarding information collected through our App, and section 4.6 regarding our use of sensitive types of information.

  Information we collect Purposes for which we use it Why we use it
a. Information related to a flight booking or purchase of our products or services, whether provided online, over the phone, in person, via email, a mobile app, self-service device or otherwise, including:
· your name and title;

· your national ID, in certain circumstances;

· your contact details, such as postal address, telephone numbers, and email address;

· your flight, luggage, and itinerary information;

· special assistance requests and preferences;

· your billing and transaction information such as credit/debit card number(s), and related data including associated billing address, and expiration date(s);

· emergency contact(s);

· medical needs, dietary and catering requests;

· flight, car, and ground transportation preferences;

· travel companions’ personal information;

· your order for other services, such as animal carriage, and inflight services such as beverages/food, and goods.

 We use this information to:
· provide you with our flight and other products and services;
· provide assistance with bookings and seat assignments;

· confirm your travel arrangements and remind you about incomplete bookings;

· take your payment and make any refunds;

· send you service communications, such as notifications of flight schedule changes, and check-in opening;

· manage and administer our services and business, including performing our record-keeping requirements;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);

· confirm your identity and to prevent fraud;

· improve our products and services, including through statistical analysis and research for program development;

· send you marketing communications, offers, and invitations to events, which may be based on our segmentation and modelling of your personal information;

· provide you with assistance in an emergency, including Promotional Partners communicating with your emergency contacts;

· share it with other airlines or charter operators for the purposes of your itinerary or re-booking you if there is a travel disruption;

· share it with our Promotional Partners for the purpose of their providing services to you;

· share it with authorized government agencies and as otherwise described in section 7.

 We use this information because:
· it is necessary to enter into and perform our contract with you to provide flights or other products or services;

· we have a legitimate business interest in assisting you with making and managing your bookings with us;

· we have a legitimate business interest in managing and administering our business and protecting it from fraud;

· in the case of information relating to your health, and dietary requirements, you have consented to our using it to meet special assistance requests and preferences;

· in the case of our storage of information related to your credit card (beyond what is necessary to process your payment), you have provided your consent;

· we have a legitimate business interest in improving and promoting our service and better understanding how customers use it;

· we have a legitimate business interest in ensuring that our technical systems operate properly;

· in the case of information that we use to send you marketing communications, we have obtained your consent;

· we must comply with certain regulatory requirements regarding emergencies and otherwise in relation to operating passenger flights. We also have a legitimate business interest in complying with legal and regulatory requirements applicable in and outside the European Economic Area (“EEA”);

· we and other airlines or charter operators have a legitimate business interest in making and operating connections between multiple flights;

· we and our Promotional Partners and other businesses that are providing services that you request have a legitimate business interest in using the information to provide their services.

· we have a legitimate business interest in protecting against risks to passengers and aircraft;

· we have legitimate business interest in streamlining customs clearance processes, aircraft weight and balance, and flight planning for our customers
b. Passenger identification information, including:
· Secure Flight Passenger Data, such as your government issued ID, name, date of birth, gender, Known Traveler Number, and Redress Number;
· Advance Passenger Information such as passport or other travel document number nationality, issue date and location, expiry date, and country of residence;
· information from the Department of Homeland Security or similar authorities responsible for security in other countries, if traveling from certain airports.		 We use this information to:
· verify your identity;
undertake security screening to enable you to travel within and between countries, as required by most governments;
· comply with legal and regulatory requirements;
· verify your identity at check-in, , or when boarding the aircraft;
· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);
· share it with governments and as otherwise described in section 7.		 We use this information because:
· we must comply with certain regulatory requirements for verifying and authenticating your identity and have a legitimate business interest in doing so to protect the security of your SkyMiles account and your travel reservations. We also have a legitimate business interest in complying with legal and regulatory requirements applicable in and outside the EEA;
· we have a legitimate business interest in ensuring that our technical systems operate properly;
· it is in the public interest to comply with such requirements which are to protect against risks to passenger and aircraft safety and unlawful cross-border activities;
· in the case of our storage of information related to your passport data (beyond what is necessary for us to provide your flight), you have provided your consent.
c. Information related to your activities with Promotional Partners, including:
· your name and contact details;

· your SkyMiles status; your SkyMiles number; your choice of SkyMiles benefits;

· your flight information;

· your membership information for Promotional Partner loyalty programs;

· your date of birth; and

· your gender.

 We use this information to:
· provide you with services related to your activity with Promotional Partners, if applicable, including mileage tracking;

· tailor our products and services for you, including anticipating your likely preferences based on information concerning your previous travel with us, previous transactions, or communications with us, any of which we may combine with other information we have about you, and which may be based on our segmentation and modelling of your personal information;

· improve our products and services, including through statistical analysis, segmentation, and research for program development;

· send you information about our products and services;

· send you marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;

· share your information with Promotional Partners as mentioned in section 7;

· facilitate the grant of any benefits granted to you pursuant to the terms of your contract with us; and

· verify and authenticate your identity; and

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not praPromotional Partnersctical)

 We use this information because:
· it is necessary to enter into and perform our contract with you;

· we have a legitimate business interest in improving our service, personalizing it for our customers, and better understanding how customers use it;

· we have a legitimate interest in managing and administering our business and protecting it from fraud;

· we have a legitimate business interest in ensuring that our technical systems operate properly;

· in the case of information that we use to send you marketing communications, we have obtained your consent;

· we have a legitimate business interest in promoting and developing our business.
d. Information related to your preferences and personal and professional interests, and your opinions of our services, including:
· information about your Internet activity;

· your survey responses;

· your responses to our marketing efforts;
· your demographics;

· your contact preferences;

· your experience with our products and services.

 We use this information to:
· provide our products and services to you;

· tailor our products and services for you based on this information alone and in combination with other information we have about you;

· improve our products and services, including through statistical analysis and research for program development;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical):

· send you marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;

· send you online messages about products and services provided by us or our Promotional Partners, and other third parties that may be of interest to you.

 We use this information because:
· we have a legitimate business interest in enabling you to manage your preferences and account details;

· we have a legitimate business interest in improving our service, personalizing it for our customers, and better understanding how customers use it;

· we have a legitimate business interest in ensuring that our technical systems operate properly;

· in the case of information that we use to send you marketing communications, we have obtained your consent;

· we have a legitimate business interest in promoting and developing our business.
e. Information from your use of our Website or App, including:
· your Internet service provider;

· your browser type;

· your operating system;

· pages you access on our Website or App;

· the date and time of your access to our Website or App;

· your device type;

· the IP address or unique identifier of your device;

· your location, established from GPS or network based features;

· feedback you provide to us;

· your on-line transactions with us.

 We use this information to:
· operate and administer our Website;

· provide our products and services to you. In the case of services provided through the App, these will be only the services you have chosen within the App, as further described in section 4.2;

· improve our products and services, including through statistical analysis and research for program development;

· send you messages and offers, about products and services provided by us or our Promotional Partners and other third parties that may be of interest to you, which may be based on your on-line behavior combined with other information we have about you and/or segmentation and modelling of your personal information;

· tailor products and services for you, based or your browsing history on our Website, and use of the App, and combining this information with other information we have about you;

· identify issues with our Website and users’ experience of it;

· monitor the way our Website is used;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);

· support your use of location-based tools, such as airport directions and map views, and city code search;

· send you information about services in your location which may be of interest;

· administer your on-line account, if you have one.

 We use this information because:
· we have a legitimate business interest in understanding how our Website is accessed, how it is used, any security issues affecting its operation, and any problems users have with it across multiple devices;

· we have a legitimate business interest in improving our service and better understanding how customers use it;

· we have a legitimate business interest in providing you with information relevant to your travel with us;

· we have a legitimate business interest in ensuring that our technical systems operate properly;

· we have a legitimate business interest in promoting our products and services and those of third parties, and in personalizing the information that our Website or App sends to you about these things;

· in the case of information that we use to send you marketing communications, we have obtained your consent.
f. Information from your communications with us and our staff, including:
· interactions in person on board our flights, or with ground staff;

· emails, letters, surveys, and telephone calls with our staff including our customer service teams;

· via social media.

 We use this information to:
· deal with any issues and concerns;

· provide our products and services to you;

· personalize our services;

· manage and administer our services and business and for our record-keeping requirements;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);

· improve our products and services, including through research for program development;

· send you marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;

· monitor communications for staff training, and quality checking purposes.

 We use this information because:
· it is necessary to enter into and perform our contract with you to provide flights or other products or services;

· we have a legitimate interest in managing and administering our business and our relationship with you;

· we have a legitimate business interest in ensuring that our technical systems operate properly;

· we have a legitimate business interest in improving and developing our products and services;

· in the case of information that we use to send you marketing communications, we have obtained your consent;

· we have a legitimate business interest in promoting and developing our business.
g. Information relating to travel and aircraft emergencies, including:
· your involvement in medical incidents affecting you and others during your travel with us;

· professional information about individuals involved in your care;

· your designated emergency contacts.

 We use this information to:
· assist you and your family members if there is an emergency;

· provide you with your program benefits;

· provide you with appropriate and timely communications;

· comply with legal and regulatory requirements;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical).

 We use this information because:
· we must comply with certain regulatory requirements regarding emergencies;

· we have a legitimate business interest in ensuring that our technical systems operate properly;

· we have a legitimate business interest in complying with legal and regulatory requirements applicable in and outside the EEA.
h. Information we receive about you from other sources, including:
· from Promotional Partners;

· from other airlines or charter operators, your and your fellow travelers’ reservations containing your names and itineraries;

· from travel agencies or brokers;

· from your employer;

· demographic information from public records and third parties;

· from financial institutions and credit checking agencies.

 We use this information to:
· provide you with flights;

· manage and administer our services and business and for our record-keeping requirements;

· combine it with other information for statistical research and marketing purposes;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical);

· develop and promote our products and services;

· check for and receive payment approval.

 We use this information because:
· it is necessary to enter into and perform our contract with you to provide flights;

· we have a legitimate business interest in improving and developing our products and services;

· we have a legitimate business interest in performing our contract with your employer;

· we have a legitimate business interest in ensuring that our technical systems operate properly.
i. Business information of travelers on corporate accounts and of representatives of suppliers and other businesses we deal with, including:
· corporate contact, and employer or affiliation (e.g., employer name, title, contact details, and contract information).		 We use this information to:
· conduct our business dealings with our suppliers, customers, and other businesses;

· tailor our products and services for you based on this information alone and in combination with other information we have about you;

· sharing your company’s information to obtain SkyBonus benefits;

· send you or your company marketing communications, offers, and invitations to events, which may be based on segmentation and modelling of your personal information;

· maintain the operational availability and reliability of our IT systems with infrastructure backups and testing (which may use a copy of live data where test data is not practical).

 We use this information because:
· we have a legitimate business interest in performing our contracts with our suppliers and other business;

· we have a legitimate business interest in developing our business with our corporate customers;

· in the case of information that we use to send you marketing communications, we have obtained your consent;

· we have a legitimate business interest in ensuring that our technical systems operate properly.

We only base our use of personal data on our legitimate interests when we consider that our legitimate interest is not overridden by the individual’s interests or rights in the data.

Please note that where you have provided your consent to us for processing your information, you can withdraw this at any time as described in section 8.

4.2. Information collected through our App

In addition to the data described in 4.1, our App may also use push notification tokens in the App to send notifications to your mobile device with updates of flight status-related information and marketing content. The App will activate your camera if you choose to take a picture for storing travel documents or reporting flight issues, and will store the photo for you to look at later. If you choose, the App can access your device calendar to save itinerary information in your personal schedule.

The App also collects “crash data” which is used to better understand why the App experienced an issue and maintained operational availability and reliability of the platform. Note: the only personal information we store “on device” from the App is the username and password, if the user chooses to do so.

At times, we may promote the App via internet advertising on external websites. If you click on these advertisements and navigate directly to a third party application or other platform, information such as your phone’s device identification number may be sent to the advertising network, so that they and we may track the effectiveness of our advertising. This information might also be used for capping the number of times a specific visitor to a website is shown a particular advertisement, estimating the number of unique users, debugging, or security and fraud detection.

4.3. Legal requirements and professional advice

We may also use your personal information where this is necessary to comply with a reasonable request by a law enforcement or regulatory authority, body, or agency, or in the defense of legal claims.

We may also use your personal information when obtaining legal and other professional advice including for audits. We consider this to be in our legitimate interest in the management of our business.

4.4. What if you do not provide information?

In some cases, we are legally required to collect certain information from you so we can provide the services you have requested, such as Secure Flight Passenger Data or Advance Passenger Information when you make a reservation to fly within, into, or out of the United States, or for point-to-point international travel. Failure to provide this information will mean we cannot provide the service.

In some circumstances we need your information to perform our contract with you or to provide products and services, such as payment details and, on occasion, credit checking information. If you do not provide this information, we may not be able to enter into or perform the contract or provide the products and services.

4.5. Authorization on behalf of another passenger

When you provide information to us about your travel companions (if, for example, you have arranged to make a booking on their behalf), you confirm to us that you have obtained their authorization to provide us their information and their consent to use their information in accordance with this Privacy Policy. If you cannot make these confirmations, you must not provide us with any personal information about these individuals.

4.6. Sensitive Information

We may collect or receive sensitive personal information, such as that relating to health, disabilities, race, ethnicity, political opinions, biometrics, or religion, where permitted by applicable law. For example, we may collect and receive sensitive personal information from you when you:

  • provide such information to us, a travel agent, broker, charter operator, or another third party involved in your travel arrangements at the time of or following your booking;
  • disclose to us that you have a specific medical condition, will have an accompanying service animal, or request specific medical care or assistance, such as the provision of an accompanying nurse or wheelchair assistance, from us, an airport, or a third party involved in your travel arrangements; or
  • make a request that implies or suggests something about you which could be interpreted as sensitive personal information, such as a request for a specific type of meal that may suggest that you have a certain medical condition or hold a particular religious belief.

By providing any personal information that is or could be sensitive personal information, you agree that you have given us your consent to collect, store, use, and transfer this personal information for the purposes for which it was provided and otherwise in accordance with the terms of this Privacy Policy.

We occasionally receive personal information from law enforcement agencies and other sources relating to criminal activity (or alleged criminal activity) and may use that information where necessary, and where permitted by applicable law, to detect or prevent unlawful activity occurring during air travel. We consider this to be in the substantial public interest.

  1. DATA RETENTION

We store your information for as long as legally required or for so long as necessary to support business purposes described in section 4 of this Privacy Policy and consistent with our record retention policies. In general, this storage will be (i) at least for the duration of our relationship, (ii) for as long as you can bring a claim against us and for us to be able to defend ourselves, and (iii) for any period required by tax, aviation, and other applicable laws and regulations.

Our App will store user-provided data for as long as you use the related feature of the App, unless you choose to delete the App. Only information provided for travel clearance, purchases, and related activities will be stored in our operational systems as needed to provide your requested services. As with the Website, if you request deletion of your 5 Skies Aviation profile, we will delete the data stored in that profile.

  1. HOW 5 SKIES AVIATION USES COOKIES, TAGS, AND SIMILAR TECHNOLOGIES

6.1. Cookies

5 Skies Aviation uses cookies, tags, and other similar technologies. For simplicity, we refer to all these technologies as “cookies”. These technologies allow us to recognize your preference information, keep track of your purchases, remember your login credentials, and facilitate effective Website administration. We use the information we collect to enhance your visit to the Website and to provide you with information tailored to your needs.

Your Internet browser(s) will offer you the option to refuse cookies, but doing so may affect your use of some portions of 5 Skies Aviation’ and our Promotional Partners’ web services. Please refer to your browser options to learn more about cookie management.

5 Skies Aviation has engaged third party tracking and advertising providers to act on 5 Skies Aviation’ behalf to track and analyze your usage of our Website through the use of cookies, pixel tags / web beacons, and similar technologies. At our request, these third parties collect, and share with us, usage information about visits to our Website, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our Website, help us target our Internet banner advertisements on our Website and on other sites, and track use of our Internet banner advertisements and other links from our marketing partners’ sites to our Website. To learn about the available mechanisms for opting out of cookies and technologies related to interest-based advertising, see the descriptions and links in the table below.

Our Website and App are not configured to read or respond to “do not track” settings or signals in your browser headings or mobile device settings, which vary by provider. In lieu of a browser- or device-based opt-out solution, we have identified in the table below certain Digital Advertising Alliance and other approved methods for placement of “opt-out” cookies. Our Website and those of our third party advertisers or other vendors are configured to read and honor these opt-out cookies, so long as they are present on your computer or device. If you delete all cookies, you will need to reset your opt-out cookies. Please be aware that 5 Skies Aviation does not control these opt-out processes.

6.2. Types of cookies and tags on our Website

We use these kinds of cookies and tags on our Website and App:

Cookie name / provider / type What these cookies do These cookies remain
Performance cookies, such as those used for Google Analytics These cookies collect information on how users use our Website, in order to help us fix technical issues or errors, and highlight areas such as navigation where we can improve our Website. For example, Google Analytics uses cookie identifiers to track the number of visitors to the Website, providing us with the volumes and sources of web page traffic. This allows us to analyze web traffic patterns and run tests to optimize web pages and visits against key metrics.
The information collected by Google Analytics itself is anonymous, but if you respond to a marketing email, then a random ID is generated for Google Analytics which we can use along with your email address to manually identify you from other information we already hold in your customer profile. We may then use this information to generate potential sales leads or advertising.
You can find more information about how Google Analytics safeguards your data at: https://policies.google.com/privacy?hl=en		 2 years from last visit to our Website or App, respectively
Targeting cookies, such as those used by advertising platforms we may use, such as Facebook or Twitter We may use other cookies to target and re-target visitors to our Website and App with digital advertising that is most relevant to the user. These cookies are also used to limit the number of times you see an advertisement or particular content, as well as help measure the effectiveness of an advertising or marketing campaign. Using existing cookies from many sites already on your computer, we partner with third party companies to deliver advertising to specific computers.
For more information about digital advertising visit AdChoices at:
https://youradchoices.com/		 More than 30 days from last visit to our Website or App, respectively
Social media cookies We allow users to share our Website on social media such as Facebook and Twitter through the use of their cookies. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work. n/a
Functionality cookies, such as language preference These cookies help us customize our Website content based on a user’s preferences. They remember the user’s choices, their language, the country pages visited, and any changes the user makes to text size or other parts of our Website pages. The information these cookies collect may be anonymized and they cannot track browsing activity on other websites. 30 days from last visit to our Website or App, respectively
Essential cookies, such as jsessionid, xssid, xssidsec, and dlsite These cookies are essential for parts of our Website or App to operate. They enable users to move around our Website and allow us to recognize a user within our Website or using our App, so that we can provide users with service they asked for, such as remembering the user’s sign-in details.
A preference cookie is required to maintain a record of your Do Not Track preferences, so that we may respect them for future visits.		 30 days from last visit to our Website or App, respectively

6.3. Website tracking preferences and opt out

To opt out of first party tracking (that is, tracking with cookies placed by 5 Skies Aviation) on our Website, you may choose from these options:

  • Email charter@5skiesaviation.comto opt out of analytics and usage tracking on our Website
  • Email charter@5skiesaviation.com to opt out of content targeting on our Website

To opt out of third party tracking (that is, tracking with cookies placed by persons other than 5 Skies Aviation):

  • Click here to visit the Network Advertising Initiative site to set preferences and opt out of third party targeting programs
  • Email charter@5skiesaviation.com to opt out of the Google Ad Network
  • Email charter@5skiesaviation.com to opt out of Google Analytics

EU visitors can find general information and opt-out resources at https://youronlinechoices.eu and US visitors can see https://aboutads.info.

6.4. App tracking preferences and opt out

You may opt out of all information collected via the App by uninstalling it. You may use the standard uninstall, application, and data management processes available through your mobile device. Once you have uninstalled the App, all information that is stored in the App is deleted, including any preferences you previously set for location permissions and whether you have allowed 5 Skies Aviation to send you push notifications. Once the App is uninstalled and preferences are deleted, push notifications from the App will stop. You may also refrain from using application features that collect specific types of data.

You may at any time opt out from allowing the App’s access to your location data by disabling location tracking features as provided in your mobile device settings.

The “limited tracking” or similar advertising-related privacy settings offered by device manufacturers do not change how your device is tracked by 5 Skies Aviation.

  1. WITH WHOM DOES 5 SKIES AVIATION SHARE YOUR INFORMATION?

7.1. In general

We do not sell your name or other personal information to third parties, and do not intend to do so in the future.

We may disclose your information we collect or receive:

  • to third parties to process your information on our behalf, or to assist us in providing our services and/or products, such as our Client Services department and providers of technical services such as data centers; however, 5 Skies Aviation requires that third parties comply with 5 Skies Aviation’ Privacy Policy when processing your information.
  • to the party providing the service or product when you request or purchase services or products through 5 Skies Aviation that are to be provided by another party (for example, a travel segment on another carrier, or rental car or ground transportation).
  • to you or those acting on your behalf. Where local regulations require, we may obtain your consent in writing for the purpose of allowing someone else to act on your behalf.
  • to our Promotional Partnersand other 5 Skies Aviation group companies for the purposes described in and in accordance with this Privacy Policy.
  • to other airlines and charter operators, including members of our SkyTeamalliance, for the purpose of servicing your travel, servicing your flight reservation, or recovering your flight in the event of an unexpected disruption in your travel.
  • to banks, financial firms and payment services for the purposes of processing payments and refunds.
  • to government agencies and authorities, law enforcement officials, law courts, or to third parties: (a) if we believe disclosure is required by applicable law, regulation or legal process (such as pursuant to a subpoena or judicial order); or (b) to protect and defend our rights, or the rights or safety of third parties, including to establish, make, or defend against legal claims.
  • to customs and immigration authorities, which require by law access to booking and travel itinerary information including “Advanced Passenger Information” (passport and associated personal information) for all passengers prior to travel.
  • to passengers traveling under the same booking as you.
  • to persons providing services to 5 Skies Aviation, including its professional advisers (e.g. auditors, lawyers, and technical consultants).
  • to persons with whom we are discussing selling any part of our business or to whom we sell any part of our business.

We may share with third parties anonymous, aggregated information about all our users.

If your travel is purchased pursuant to a corporate incentive agreement, we may disclose information concerning your travel to your employer or corporate travel manager.

When you use the App, a unique ID (which varies by device manufacturer and operating system) is read from or associated with your device to be used as an anonymous identifier for analytics and performance purposes. This ID might be generated by or shared with third parties providing us with analytics services, such as Adobe.

7.2. Sharing With Social Media

You may wish to share information regarding your travel or other activities with 5 Skies Aviation on social media platforms provided by third parties. To utilize social media sharing features, you will be prompted to grant permissions within those third-party platforms, as you choose. For example, you will need to allow account login and publishing permissions. If you choose to contact or interact with us on a third-party social media platform, you understand that you are responsible for reviewing and understanding the terms and conditions, information security practices, and privacy policy applicable to the third-party platform, and that 5 Skies Aviation is not responsible for how third-party social media platforms use, share, or protect your information. The activity on third-party social media platforms, and the data processed, stored, and provided on them, including data regarding interactions with 5 Skies Aviation, is governed by the terms and conditions, information security practices, and privacy policy of those third-party platforms.

 

7.3. Disclosure of personal information to passengers travelling under the same booking

When you make a booking, you will be provided with a booking reference such as a confirmation number or record locator number. Your booking reference should be kept confidential at all times. Disclosing your booking reference to other passengers may allow them to access your booking details through our systems. If you are travelling with others under the same booking and would not like your individual booking details to be disclosed to them, you may disclose this to our Client Services team.

  1. CORRECTING OR UPDATING YOUR INFORMATION OR MARKETING PREFERENCES

If you believe that any information we hold about you is incorrect or incomplete, or if you want to change your marketing preferences, you have a number of options:

  • Email charter@5skiesaviation.com if you want to modify your subscription, email or contact preferences in relation to Promotional Partners.
  • You can withdraw consent you have given us to process your information at any time by emailing charter@5skiesaviation.com
  • You may email charter@5skiesaviation.comif you have questions about removing your name from our subscription lists.

We will make reasonable efforts to revise any information that is incorrect, or update or change your information or preferences as we are required to do by applicable law.

Please see section 6 regarding consents to cookies and tracking.

  1. YOUR RIGHTS

This section 9 applies only to individuals in the European Union and other countries which grant the rights described here. These rights will apply only in certain circumstances.

9.1. Requesting a copy of your information

To the extent you are legally entitled, you can request confirmation of whether or not we process your personal information, and details of the information that we hold about you and how we use it.

You also have a right to access your personal information and to be provided with a copy.

9.2. Right to rectification of personal data

If you believe that the personal data we hold about you is inaccurate, you may request that we correct it. You may also request us to complete personal data about you which is incomplete.

9.3. Right to restrict processing of personal data

You have the right to request that we restrict processing of your personal information where one of the following applies:

  • You claim that the personal data is not accurate. The restriction will apply until we have taken steps to ensure the accuracy of the personal data.
  • The processing is unlawful, but you do not want us to erase the personal data.
  • We no longer require the personal data for the purposes of processing, but you still need it in connection with a legal claim.
  • You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing

9.4. Right to request deletion of personal data (“right to be forgotten”)

You may request the erasure of your personal information in certain circumstances. For example, you may request erasure if:

  • The personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
  • You have withdrawn your consent and we have no other legal basis for processing the personal information.
  • You have exercised your right to object to processing the personal information, and we have no overriding legitimate grounds to continue processing it.

Under certain circumstances, we may refuse a request for erasure, for example, where we need to use the personal data to comply with a legal obligation or to establish, make or defend legal claims.

If you exercise your right to erasure, this will potentially remove records which we hold for your benefit, such as your account login information and your presence on a marketing suppression list.

9.5. Right to object to processing of personal data

You have a right, at any stage, to object to our using your personal information to send you marketing information.

You also have the right to object to our using your personal information where our reason is based on our legitimate interests. We will have to stop processing until we can establish that we have compelling legitimate grounds which override your interests, rights, and freedoms, or that we need to continue using it for the establishment, exercise, or defense of legal claims.

9.6. Right to data portability

This right applies where:

  • Our reason for using your personal information is either that you have given consent or that the processing is necessary for us to perform a contract with you; and
  • We process the personal information by automated means.

This is a right to receive all the personal information which you have provided to us in a structured, commonly used, and machine-readable format and to transmit this to another controller directly, where this is technically feasible.

9.7. Complaints to regulator

You have a right to complain to a supervisory authority (i.e., a regulator which oversees data protection law compliance), in particular, in the European Union country where you live or work or where you consider we have infringed on your privacy rights.

9.8. Exercising these rights

We may charge you a small administration fee to respond to your request as allowed by applicable law. In general, we do not charge any fee where the right is based on European Union law. (We can charge an administrative fee for extra copies of your information and in certain exceptional circumstances.)

Where we receive a request to exercise one of these rights, we will provide information on the action we take on the request without undue delay and in any event within one month of receipt of the request. This time may be extended by a further two months in certain circumstances, for example, where requests are complex or numerous.

Where we do not carry out your request, we will tell you without delay and in any event within one month of receipt of the request, and we will explain our reasons for not taking the action requested.

Any request you make must be in writing and include your name and address and any other information that may identify you, such as where your request relates to a travel booking, please provide your booking reference (e.g., confirmation number or record locator number), 5 Skies Aviation Account username if you have one, the dates on which the travel took place, and any other relevant information that will assist us to identify your booking. You must also provide a photocopy of your passport or driver’s license so we can verify your identity. Please send your written requests to our Data Protection Officer by emailing us at charter@5skiesaviation.com.

  1. MINORS

We will remove the information and unsubscribe the child from any of our electronic marketing lists. Where required by applicable law, we may ask children for consent from their parents or guardians before we book their flight or provide a product or service to them.

  1. LINKS

Our Website contains links to other sites. We are not responsible for the content or privacy practices of those sites, and 5 Skies Aviation’ Privacy Policy does not apply to information collected from you by those sites. We encourage you to read the privacy statements of each site that collects information from you. When you are leaving our Website via a link to interact with a site that is not governed by our Privacy Policy, a new browser window will open.

  1. SECURITY

Information Security is important to 5 Skies Aviation. We have established appropriate physical, electronic, and managerial safeguards to protect the information we collect in accordance with our Privacy Policy. These safeguards are regularly reviewed to protect against unauthorized access, disclosure, and improper use of your information, and to maintain the accuracy and integrity of that data.

  1. PROMOTIONAL PARTNERS

We want to give you more opportunities to earn promotional benefits and opportunities and one of the ways we do this is by sharing your information with Promotional Partners. Typically, these promotional offerings are limited in quantity and geographic reach and targeted to specific demographic audiences. If you fall within the audience a Promotional Partner is trying to reach, and (where required under applicable law) you have consented to receive information about their services, you may receive a promotional e-mail or direct mail. Although we select our partners with care, these partners have their own privacy policies that apply to the way they use your personal data.

If you do not want us to share your information with one of these partners, you can always opt out by contacting us by emailing charter@5skiesaviation.com

  1. DATA TRANSFERS

5 Skies Aviation is based in Van Nuys, California, USA and we may transfer personal information in compliance with applicable law to the US and other jurisdictions where 5 Skies Aviation provides services.

In some limited circumstances, we may also transfer your information outside the EEA if the GDPR (under Article 49) allows this. This includes where it is necessary for the performance of a contract between us and you and where the transfer is necessary in connection with legal proceedings.

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