What this Policy Covers
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- What information do we collect about you
- How we use the information we collect
- How we share information we collect
- How we store and secure the information we collect
- How to access and control your information
- How we transfer information we collect internationally
- Other important privacy information
This Privacy Policy covers the information we collect about you when you use our product or services, or otherwise interact with us (for example, by communicating with us), unless a different policy is displayed. ExecuJet, we and us refer to ExecuJet Aviation (Pty) Ltd. You refer to the customers and any other third party with whom ExecuJet contract, either to whom ExecuJet provide the services, or who assist ExecuJet in providing the services.
This policy also explains your choices surrounding how we use information about you, which include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
Where we provide the Services under contract with an organization (for example, third party handling agents) that organization controls the information processed by the Services. For more information, please see Notice to End Users below.
What Information Do We Collect About You
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below. For purpose of this policy, customers (also referred to as you) include potential and existing customers.
Information You Provide to Us
We collect information about you when you provide it directly to us.
Account and Profile Information: We collect information about you and when you obtain a quotation for a charter flight or book a charter flight through the Services. For example, you provide your contact information and, in some cases, billing information.
The content you provide through our product: The Services include the ExecuJet products you use. We keep track of your preferences when you select criteria within our Services. This content includes any information about you that you may choose to include, namely: the type of flights that are conducted, the type of aircraft that is utilized, the typical number of passengers on board the aircraft, destinations that are selected, departure airports that are selected, type of meal plans selected, and any specific requirements that are requested.
The content you provide through our website: The Services also include our website owned or operated by us. We collect other content that you submit to this website, which includes social media or social networking sites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, activities, or events.
Cookies and Other Tracking Technologies: ExecuJet and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g. web beacons, device identifiers, and pixels) to provide functionality and to recognize you across our Services and devices.
How We Use Personal Information
Your personal information will only be used for the purpose for which it was collected and agreed upon. Below are the specific purposes for which we use the information we collect about you:
- To provide the Services and personalize your experience: We use information about you to provide the Services to you, including processing transactions with you, authenticate you when you deal with ExecuJet, provide customer support, and operate, maintain, and improve the Services. To opt-out of this personalization, please contact privacy@ExecuJet.co.za
- For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful. We use the information and collective learnings (including feedback) about how people use our Services to troubleshoot, identify trends, usage, activity patterns, and areas for integration and to improve our Services, and to develop new products, features, and technologies that benefit our customers
- To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your charter enquiry, reminding you of passenger name and payment expirations, confirming payment, providing tickets and an itinerary, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages in respect of prospective flights
- To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use the information for the detection and prevention of fraud, crime, money laundering or other malpractice, and in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business
Section 11 of POPI Act prescribes that personal information may only be processed if certain conditions are met which are listed below along with supporting information for the processing of personal information:
- Customers consent to the processing: consent is obtained from you during the introductory stage of our relationship either verbally, written, or tacitly
- The processing is necessary: in order to deliver products and services to you, certain personal information is required. Processing is furthermore necessary to conclude a contract between the parties
- Processing protects a legitimate interest of the data subject: We need to collect and process personal data in order to provide you with information regarding our required service and products. You will benefit from having the aircraft details updated and in an accessible format as a value-added service from us.
Legal Bases for Processing (For EEA Users)
- If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where
- We need it to provide you the Services, including operating the Services, provide customer support and personalized features, and protecting the safety and security of the Services
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, and to protect our legal rights and interests
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services.
Disclosure of Personal Information
This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible commercial opportunities. Our business is not that of selling information about you to advertisers or other third parties.
Sharing with other Service Providers: When you use the Services, we share certain information about you with other Service providers. We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Services. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.
How we Store and Secure Personal Information
- Information storage and security: We use industry-standard technical and organizational measures to secure the information we store. We are committed to adequately protect the personal information we hold and to avoid unauthorised access and use of personal information. We will continuously review our security controls and processes to ensure that personal information is secure
- We have implemented the following procedures in order to protect personal information
- ExecuJet’s Chief Information Officer, whose details are available below, is responsible for the encouragement of compliance with the conditions of the lawful processing of Personal Information and other provisions of applicable legislation
- This policy has been put in place throughout ExecuJet and training on this policy will take place
- Each employee’s employment contract contains a confidentiality clause
- Our archived customer information is stored at our head office, in a secure area with limited and controlled access
- Our electronic server and database are backed up to a secure online server daily. ExecuJet’s electronic and IT safety is performed by our Chief Information Officer
- Consent to process your information is obtained from you during the introductory stage of our relationship either verbally, written, or tacitly
How We Trasfer Personal Information Internationally
We collect information globally and may transfer, process, and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
International transfers within the ExecuJet Group of Companies: To facilitate our global operations, we transfer information globally and allow access to that information from countries in which the ExecuJet Group of companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we share information about you within and among ExecuJet corporate affiliates, we make use of standard contractual data protection clauses, which have been approved by the European Commission (Art. 46 GDPR), and we rely on the EU-U.S. and Swiss-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area, the United Kingdom (the "UK"), and Switzerland.
Other Important Privacy Information
Notice to End Users: Many of our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.
Changes to our Privacy Policy: We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.
Contact Us: Your information is controlled by ExecuJet (Pty) Ltd. If you have questions or concerns about how your information is handled, or if you wish to ask us to update, correct, or delete your personal information on reasonable grounds, please direct your inquiry to the Chief Information Officer, which we have appointed to be responsible for facilitating such inquiries and whose contact details are as follows:
Designation: Chief Information Officer
Postal Address: P.O. Box 2, Lanseria, 1748
Physical Address: Entrance 1, Lanseria International Airport, Lanseria, Gauteng
Telephone number: 011 516 2300
Email Address: Pieter.steyn@luxaviation.com
We will take all reasonable steps to confirm your identity before providing details of your personal information or making changes to your personal information.
General
Blogs, Social Media, and Public Forums: We may offer blogs, social media profiles, message boards, bulletin boards or similar public forums where you and other users of our Service can post content or otherwise communicate. If you post information on a public forum, we will assume you intend to make that information public. We may use your name to identify you with a posting in a public forum and may use your post on or in connection with our Service (e.g., when using a hashtag associated with us in a tweet or status update). Any information you share in a public forum is public information and may be seen or collected by other persons, including third parties that do not adhere to the standards set forth in this Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our online services.
Clear Gifs and Log Files: We, and our third-party partners, use technologies such as web beacons in analysing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically-collected data to other information we collect about you.