Privacy Policy – Regius Private Jets

Regius Jets

Introduction

The following provisions constitute the current Privacy Policy issued by Regius Jets Ltd. a company incorporated under the laws of Malta with registration number C95742 (hereinafter referred to as “we”, “us” or “our”). Your privacy is important to us and we are committed to ensure confidentiality, accuracy and security of your personal data that we collect about you (hereinafter referred to as “you,” “your” or “user”).

Any information you provide to us shall be collected and processed fairly, lawfully and in accordance with this Privacy Policy and any relevant data protection laws and regulations applicable from time to time, including the Data Protection Act (Chapter 586 of the Laws of Malta) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as may be amended from time to time.

This Privacy Policy explains the manner in which we collect and use your Personal Data as our client or potential client, when you use our Website www.regiusjets.com, our mobile application, our content, services and products and when contacting us through our customer care centre. Moreover, this Privacy Policy also applies to you when you enter into an agreement with us to make use of our services and products, which services and products may be subject to their own terms and conditions. In case of any conflict between this Privacy Policy and the terms and conditions of any such services and products, then the latter shall prevail.

The Controller of Personal Data

The Data Controller responsible for your Personal Data is:

Regius Jets Ltd.
50, Flat 1, Warren Complex,
Triq V. Menville, Ibragg,
Swieqi, SWQ 2160

Company registration number C95742

What is Personal Data?

Personal data refers to any information that identifies you and that we may collect, use, share, store and transfer in physical or electronic form.

Legal Basis for Processing Personal Information

We have the following lawful basis to process your personal information:

To operate the Website and to provide you with our services and products;
To monitor and improve the Website and our services and products;
To administer your account by creating and managing your account, provide you with customer support and respond to your requests;
To communicate with you about your account, our services, products and the Website;
To comply with our legal and regulatory obligations and to enforce the Terms and Conditions of our Website, services and products.
To establish, exercise or defend legal claims or proceedings;
To prevent, detect and fight fraud or other illegal or unauthorised activities;
To communicate with you by email about products or services that we think may interest you;
From time to time, we may ask for your consent to use your Personal Data for certain specific reasons such as for example, to send you marketing material which we think may be suitable for you, including any relevant promotions and offers. Such marketing communications will only be sent to you if you have consented thereto through an ‘Opt-in’.

Which Personal Data do we collect and how do we use it?

When you register on our Website and create an account, we may collect and use any type of Personal Data which is entrusted to us, including the following kinds of personal data:

Identity Identification such as, name & surname, title, nationality, date of birth, residential address, telephone phone and/or mobile number, photographs, including passport, visa or other identification documents when you book a flight with us;

We may use Identity Information for the following reasons:

To fulfil any agreement, we may have with you and to meet our contractual obligations stipulated therein;
To carry out the necessary due diligence or other background checks on you and to ensure that you are not subject to any economic or trade sanction legislation or travel ban/s;
To send you service communication by email, telephone, SMS or otherwise;
To reply to any communications that you might send us from time to time;
To create and manage your account on the Website;
To comply with our legal and regulatory obligations;
For statistical analysis purposes;
For the establishment, exercise and/or defence of legal proceedings or claims;
For recruitment and employment purposes;
To record and deal with complaints we may receive;
For security and verification of identity;
To improve our Website and services by sending you feedback from time to time;
To send periodic communications to keep you informed about the services that we provide you with as well as other updates, security alerts and support messages

Please note that we may use your email address to confirm your opening of an account, to remind you to complete the registration process and to send you other important notices and changes which may occur from time to time. At times, we can also use your email address to confirm or otherwise any changes you may make to your account. Since these emails are not of a marketing nature, you cannot choose to opt out from receiving this type of communication from us.

Financial information such as bank account details and payment card information (including information received from third party credit and financial institutions)

We may use Financial Information for the following reasons:

To withdraw payments and offer refunds
For security, fraud prevention and detection

Transactional information that includes details relating to previous bookings, and other products or services that you may have purchased from us in the past;

We may use Transactional Information for the following reasons:

To provide customer care and support;
To handle bookings;
To see what products and services you are interested in;

Technical information such as Internet Protocol Address, browser type and version, operating system, date/time stamp, geographical location, browser plug-in types and other technological information relating to the device you use to access our Website;

We may use Technical Information for the following reasons:

To improve and to keep our Website secure;
To see what products and services you are interested in;

Technical Information may be collected by using cookies and other similar technologies, as explained in this Privacy Policy and the Cookie Policy. We may also receive information relating to you from third parties including, analytic providers and advertising networks.

Contact History Information includes records of details that you have provided us with when communicating with us by email, on social media platforms and when you contact our customer care centre.

We may use Contact History Information for the following reasons:

To train our staff;
To provide customer service and support;

Other Information such as your food preferences, travel arrangements including your travel itinerary and any other information that you may voluntarily provide us with. Such information may include personal data that you may provide to us directly or through companies and/or agents that we work with.

Marketing Communications

We may use Marketing Information for the following reasons:

To communicate with you by email, SMS or other means and let you know about our products and services;
To ask you to provide us with your feedback
To personalise your travel experience according to your interests

Please note that where your personal data is used by us, and you have a choice for example to receive direct marketing, you will always be afforded the option of stopping further contact by unsubscribing and controlling these consent options.

Sensitive Personal Data

Certain categories of personal data are considered to be sensitive by nature, such as information relating to ethnicity, race, religion or health. When providing you with our services, we may ask you to provide us with sensitive personal data that relates to your health and medical conditions, including any allergies and any underlying health issues that you may suffer from. We will process sensitive personal data where you have requested specific medical assistance, or you have indicated that you suffer from a medical condition, or you inform us that you are pregnant, or you have otherwise voluntarily chosen to provide us with such information when booking a flight through our services. By providing such information that may be considered as sensitive personal data, you explicitly agree that we may process such personal data with third parties and to transfer such data, within and outside the European Economic Area.

Disclosure of Personal Data

There may be instances where we have to share your personal data with various categories of persons. We may disclose your personal data to our employees and our authorised representatives who may be assigned to carry out our functions to provide you with our services and products.

Your personal data may also be disclosed to third-party service providers, including airplane operators and actual carriers, as defined by applicable legislation, and any other third-party service providers that may assist us in providing you with our services. When we share your personal information with such third parties, we make sure that such parties make use of this data in a manner which ensures safety and security to your Personal Data.

We may disclose your Personal Data to other companies which may make part of the group of companies that we may form part of from time to time. We may also disclose your Personal Data to enforcement/government/legal authorities if we are required to comply with any applicable law, a summons, a warrant, a court or regulatory order, or any other statutory requirement, in the case we have reason to suspect any form of illegal usage of our services and products. We also reserve the right to, on a voluntary ex officio basis, share your Personal Data with relevant law enforcement agencies in connection with any investigation of suspected or actual illegal activity. Moreover, we may be obliged to share your Personal Data with any customs and immigration authority, when required to do so in terms of law.

Your information will not be supplied, sold, rented or traded to others for any reason without your prior written consent.

When do we collect your Personal Data?

We may collect your Personal Data when you may make use of our services and products, when you use our Website and/or mobile application, when communicating with us through our Website, our social media platforms, mobile application or call centre, when entering into competitions or promotions that we may offer from to time and where you provide us with your feedback.

We may receive your Personal Data from other third parties including companies engaged by us to provide you with a particular service.

Your Rights at Law:

The rights afforded to yourself in connection to your Personal Data are the following:

Right of Access: the right to obtain for us confirmation as to whether or not personal data concerning you is being processed, and where that is the case, access to the such Personal Data and any other additional information as outlined in the regulations. Limitations to this right will only be applicable if provided in terms of law. We will try our best to process your request within 1 month, or 2 months if the request is particularly complex;
Right to Rectification: the right to request for your personal data to be amended or updated where it is inaccurate or incomplete;
Right to Erasure (“Right to be Forgotten”): the right to request that we delete your personal data, subject to our legal obligations and, the exercise or defence of any legal claims
Right to stop direct marketing messages;
Right to Restrict: the right to request that we stop processing all or some of your personal data;
Right to Object: the right to object at any time, to object to us processing your personal data on grounds relating to your particular situation and the right to object to your personal data being processed for direct marketing purposes;
Right to Data Portability: the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
Right not to be subject to Automated Decision-making: the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect;
The right to complain to your data protection regulator. In Malta, the data protection regulator is the Information and Data Protection Commissioner that may be contacted by using the following link https://idpc.org.mt/en/Pages/contact/complaints.aspx

You will not be requested to pay any fees to access your data unless your request is unfounded, repetitive or excessive.

Retention Period of Personal Data

We will retain your Personal Data for as long as we need it for our legitimate business purposes and as permitted by applicable law. We reserve to the right to retain and access your data even if your account is closed for our legitimate business purposes (such as fraud prevention and enhancing the users’ safety and security) or we are required to comply with applicable laws.

Upon your request, we will delete or anonymise your Personal Data so that it no longer identifies you. However, this is limited as there are instances in which we are legally obliged by law to retain your Personal Data. These may include situations where we are legally obliged to keep your Personal Data where there is an unresolved issue/claim/dispute relating to yourself for a specified period of time and where it is necessary for our legitimate interests, such as fraud and crime prevention. After it is no longer necessary to us to retain your personal data, we may anonymise part of your data for analytical purposes and dispose the rest in a secure manner.

Marketing Communications

We may use your information such as your email address to send you information that we may think it is of interest to you. You will only receive marketing communications if you have requested such information yourself or booked a flight through our services, and in each case, you have not opted out from receiving such type of communications.

You may choose to stop receiving marketing communications from us by contacting us at [email protected] or by clicking on the ‘unsubscribe’ button found within the email itself.

Security of Your Personal Data

Please note that no method of transmission over the internet or method of electronic storage is fully secure. Therefore, please be aware that while we will take all necessary steps to ensure the protection of your data, we cannot provide any guarantee should the security be compromised through no fault of our own.

However, we will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your Personal Data by adopting appropriate data collection, storage and processing practices and carry out periodic reviews of same, such as the use of encryption, secure servers, use of firewalls and the use of back-up systems.

We may suspend your use of all or part of the Website without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please contact us at [email protected].

Transfer of Personal Data to Third Countries

Where the need arises to transfer your Personal Data outside the European Union, we will ensure that such information is transferred in accordance with appropriate clauses to ensure adequate technical and organisational security measures.

Job Applicants

As part of our recruitment process, or in case you send us a Curriculum Vitae in connection to a job application through our Website, we reserve the right to collect and process such Personal Data. If your application is unsuccessful, we may keep this information on file for up to one year in case of any future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose, and you are free to withdraw your consent at any time.

We will only ask for your information that is necessary to fulfil our indicated purpose to process your application or to fulfil any legal or regulatory requirements. Your information will only be used to assess your suitability for employment.

Changes to this Privacy Policy

Please note that this Privacy Policy may occasionally change from time to time and where appropriate we shall notify you with any changes made. Therefore, we encourage you to refer to this policy periodically.

Complaints and Concerns

If you have any concerns with regards to our privacy methods and processes, you may contact us at [email protected]

Last Updated: 8th July 2020