PRIVACY POLICY

1. Data Controller

The Data Controller responsible for your personal information is:

For any data protection matter, you may contact us directly at the address above.

2. Data We Collect

To arrange and manage your charter or cargo service, and to optimise your experience on our platforms, we collect the following categories of personal data:

• Identity & Travel Documents: Full names, dates of birth, nationalities, and passport or government-issued ID details required for official flight manifests and aviation security compliance.
• Contact Information: Email addresses, phone numbers, and communication preferences provided through our enquiry forms, WhatsApp, or direct contact.
• Special Requirements: Dietary preferences and relevant medical information necessary for in-flight catering, accessibility, or safety arrangements.
• Financial Information: Payment details and billing addresses required to process transactions securely.
• Commercial Correspondence: Records of emails, messages, and enquiries exchanged with our team in connection with booking or service requests.
• Digital & Behavioural Data: IP addresses, browser type, device information, and interaction patterns collected automatically when you visit www.primejetbrokerage.com via cookies and tracking technologies (see Section 7).

We do not knowingly collect personal data from individuals under the age of 16, except where strictly necessary to arrange travel for minor passengers as requested by an authorised adult client, and solely for that purpose.

3. Purpose & Legal Basis for Processing

We process your personal data only where we have a valid legal basis to do so under the GDPR. The table below sets out our purposes and their respective legal bases:

• Arranging and managing charter and cargo services — Legal basis: Performance of a contract (Art. 6(1)(b) GDPR).
• Coordinating with certified Aircraft Operators, ground handlers, and airport authorities — Legal basis: Performance of a contract and compliance with legal obligations (Art. 6(1)(b) and (c) GDPR).
• Fulfilling international aviation security, immigration, and customs obligations — Legal basis: Compliance with legal obligations (Art. 6(1)(c) GDPR).
• Sending direct marketing communications (newsletters, offers, tailored opportunities) — Legal basis: Your explicit consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time by contacting us or using the unsubscribe link in any communication.
• Improving our website and services through analytics — Legal basis: Legitimate interests (Art. 6(1)(f) GDPR), provided those interests are not overridden by your rights and freedoms. You may object to this processing at any time.
• Fraud prevention and platform security — Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

4. Data Sharing & International Transfers

As an international broker, the execution of your flight or cargo shipment requires sharing specific data on a strict need-to-know basis with trusted third parties, including:

• Certified Air Operators (AOC holders) executing the flight.
• International airport authorities, immigration and customs agencies.
• Ground handling (FBO) services, VIP catering providers, and security personnel.
• Payment processors and financial institutions for transaction handling.
• Analytics and advertising platforms (Google Analytics, Meta) solely in accordance with your consent choices.

Some of these transfers may occur outside the European Economic Area (EEA). Where this is the case, we ensure that adequate safeguards are in place — including Standard Contractual Clauses (SCCs) approved by the European Commission — to protect your data to the same standard as within the EEA.

We never sell your personal data to third parties.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legal obligations. Our standard retention periods are as follows:

• Client and booking data: 36 months from the date of the last booking or communication, in line with Spanish accounting and tax law obligations. This period resets with each new communication or booking.
• Flight manifest and aviation security data: Retained for the period required by applicable aviation authorities and international regulations.
• Marketing data: Retained until you withdraw your consent or opt out, whichever is earlier.
• Enquiry and contact data (non-clients): 12 months from the date of initial contact, unless a booking relationship is established.

On expiry of the applicable retention period, your data is securely deleted or anonymised.

6. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights, which you may exercise at any time by contacting us at info@primejetbrokerage.com:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of any inaccurate or incomplete data.
• Right to Erasure: You may request deletion of your personal data where there is no legitimate reason for us to continue processing it.
• Right to Restriction: You may request that we restrict the processing of your data in certain circumstances.
• Right to Data Portability: You may request that we transfer your data to another controller in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

We will respond to all requests within 30 days. In complex cases, this period may be extended by a further 60 days, of which we will notify you.

You also have the right to lodge a complaint with the competent supervisory authority. For Spain, this is the Agencia Española de Protección de Datos (AEPD) at www.aepd.es.

7. Cookies & Tracking Technologies

Our website uses cookies and similar tracking technologies to improve functionality, analyse usage, and deliver relevant content. The technologies we use include:

• Essential Cookies: Required for the website to function correctly. These cannot be disabled.
• Analytics Cookies (Google Analytics): Used to understand how visitors interact with our site — pages visited, time spent, and traffic sources. Data is aggregated and anonymised. You may opt out via Google's opt-out tool or your browser settings.
• Marketing Pixels (Meta Pixel): Used to measure the effectiveness of our advertising on Meta platforms (Facebook, Instagram) and to show relevant ads to users who have visited our site. This is only activated with your explicit consent. You may manage your preferences via the Meta Ads Settings.

You may accept or decline non-essential cookies via our cookie consent banner when you first visit the site, or at any time by adjusting your browser settings. Please note that disabling certain cookies may affect your experience on our website.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include encrypted communications, restricted access controls, and secure data storage practices. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. Amendments to This Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, legal obligations, or service offerings. The most current version will always be available at www.primejetbrokerage.com. Where changes are material, we will notify active clients by email. Continued use of our services following any update constitutes acceptance of the revised Policy.