The aim of this document is to explain how Simply Jet (hereafter also referred as “we” or “us”) collects, processes and protects personal data that you provide when communicating with us through any media, included but not limited to Simply Jet’s online flight request form, chat, phone, emails and texts.
This information is required to be provided by the General Data Protection Regulation (article 13; Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016).
Please note that Simply Jet does not carry out any automated decision-making.
The data controller is Simply Jet Ltd, with registered office at Rue Haldimand 4, 1003 Lausanne, Switzerland.
For any data protection concern, please contact Yann-Guillaume Jaccard at the address firstname.lastname@example.org or call +41 414 104 414.
Simply Jet collects personal data for the following purposes:
a. To provide our services to you
This is the main reason why we need to collect personal data. We need information about you for answering flights requests (made with our online form, by phone or chat), making flights offers, drafting and concluding aircraft charter service contracts, sending invoices, organising and following up flights.
In this regard, the collection of personal data is a contractual requirement, and not a statutory one. It is a condition to enter into any contract with Simply Jet. If you fail to provide required data, it can lead to the impossibility of concluding a contract and Simply Jet will not be able to provide the requested services.
For this purpose, the legitimate ground for personal data collection is the necessity to process personal data in order to enter into a contract with us.
b. To improve your customer experience
We process your personal data to improve our services. This includes tailoring our services to your needs and preferences, facilitating the use of our website by analysing the browsing history its users and sending promotional contents by post, email or online advertisement.
If you have requested to use or have used our services and have provided personal data to Simply Jet in this context, we may use your contact details to send you marketing emails about similar services, unless you have opted out. You can opt out at any time by clicking on “unsubscribe” in promotional emails or by contacting us at the address displayed here above.
For this purpose, the legitimate ground for personal data collection is Simply Jet’s legitimate interests in offering better services.
c. To comply with the law
In some cases, we are legally required to collect some personal data. This is the case when banks conduct anti-fraud checks or in the event of formal request by a government entity.
For this purpose, the legal ground for personal data collection is the compliance with a legal obligation.
Collected personal data includes:
- Contact details, such as name and surname, phone number, email address, and physical address;
- Personal details, such as family members, personal preferences, pets;
- Travel information, such as passport details, aircraft and catering preferences, departure location, destination and time of your flights;
- Bank details, when a credit card is used to book or pay for our services;
- Usage Data, which includes information history of your use of Simply Jet's services and website.
Collected data are processed by the employees of Simply Jet. The number of employees having access to your data is limited to those whose assistance is needed for the intended activity.
In addition, under the circumstances listed below, we will share your personal data with the following people:
- When an aircraft charter service contract is concluded with you: People whose intervention is mandatory to perform the contract (i. e. operators, airport terminal staff…);
- When we need to store your data: Cloud storage providers;
- When we communicate by e-mail with you: Email services providers;
- When you use our website: Analytic tools and the website’s IT developers;
- Upon payment, when we are asked to provide information against fraud: Banks;
- When you book or pay with a credit card: E-payment interface provider and payment service providers;
- When you use our chat: Chat service provider.
Depending on the service you ask for, your personal data may be transferred to a country outside of EU (third country). This can be the case if you wish to travel to or from such a third country, if you are staying in such a third country when data is transferred to or from Simply Jet or if the operator chosen is based in a third country.
In all of the above situations, the transfer is based on the necessity to process personal data in order to enter into a contract with you.
Personal data are stored as long as necessary to fulfil the purposes set out here above. This means that data will generally be stored for the time needed for the performance of the contract and possible future contracts with Simply Jet. Some personal data will be stored longer for us to comply with legal obligations, such as tax purposes.
The information is securely stored in a systematic way that ensures that nobody outside Simply Jet can access it.
Each new employee receives a training in data protection in order to know how to handle personal data of our customers.
Under the General Data Protection Regulation, you have the following rights:
a. Right to request access to personal data (art. 15 of the Regulation)
This right allows you ask Simply Jet if you want to know and see what personal data we store about you.
b. Right to request rectification of personal data (art. 16 of the Regulation)
If some personal data we hold about you is incorrect, you can ask Simply Jet it to rectify it.
c. Right to request erasure of personal data, also referred to as the “right to be forgotten” (art. 17 of the Regulation)
This right allows you to ask us to suppress personal data under specific circumstances, for example the personal data are no longer necessary in relation to the purposes for which they were collected, when processing is based on consent and you withdraw your consent, or when your personal data have been unlawfully processed.
d. Right to restrict the processing of personal data (art. 18 of the Regulation)
You can ask Simply Jet to restrict the processing of your personal under specific circumstances. It is the case when you exercise the right of rectification – you can ask for a restriction of the processing while we verify the accuracy of the concerned data. You can also exercise this right when the processing is unlawful, instead of asking for erasure (see right no. 3 above). Restriction of processing can as well be requested when we do no longer need the personal data for processing, but you require them for legal claims.
e. Right to object to the processing of personal data (art. 21 of the Regulation)
When your data is used for the improvement of our services or direct marketing, you can object to the processing. With regard to promotional emails, you can opt out by clicking on “unsubscribe” in the emails or by contacting us at the address displayed here under.
f. Right to data portability (art. 20 of the Regulation)
This right enables you to receive the personal data concerning yourself, which you have provided to Simply Jet, in an easily readable format and transmit those data to another data controller.
g. Right to lodge a complaint with a supervisory authority
This right enables you to address a complaint to the competent supervisory authority of the concerned Member state.
If you want to exercise any of rights (a)-(g) listed above, or if you have any enquiry about data protection, please send your request to Yann-Guillaume Jaccard, at the following email address: email@example.com.
Lausanne, 13 may 2018