1.1 Jet Setters Lifestyle (“Jet Setters") is committed to safeguarding the privacy of visitors to our app. Please read the following policy to understand how your information will be treated and how we look after your personal data when you visit our website or the Jet Setters Lifestyle app (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you..You are not required to provide any personal information on the public areas of this app. However, you may choose to do so by signing up and joining for free or upgrading to one of the membership levels. We want to ensure you get the most out of the service, whilst safeguarding your privacy.
This Privacy Notice sets out the basis on which any personal data that Jet Setters collects from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.
1.2 Jet Setters acknowledges that the information you provide may be confidential. Jet Setters will maintain the confidentiality of and protect your information in accordance with the company’s normal procedures and all applicable laws.
1.3 Jet Setters has a legal obligation to ensure that your information is kept accurate and up to date. Please assist us to comply with this obligation by ensuring that you inform us of any changes to your information. You have the right to request details of the information we hold about you and to delete or rectify any inaccurate information about you by sending us a written request.
2. HOW JET SETTERS COLLECTS YOUR PERSONAL DATA
2.1 We use different methods to collect data from and about you, and may obtain data from a range of different sources. These are summarized below.
2.2 Personal data that we receive directly from you. You may give us your identification data and contact data by filling in forms or by corresponding with us by email. This includes personal data you provide when you
sign up to the Jet Setters Lifestyle service and create an account,
subscribe to a membership level,
request marketing to be sent to you or
provide us with some feedback
when you verify with email.
Personal data that we receive by technical means based on your use of the service. As you interact with our website and/or app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see the section on cookies below for further details.
3. LAWFUL BASIS OF PROCESSING
3.1 In order to comply with data protection law, it is necessary for the person or organisation using the personal data to show what is known as a “lawful basis of processing”. In the case of Jet Setters Lifestyle, we will generally only use your personal data on the following basis:
where we need to perform the contract we have entered into with you to provide the Jet Setters Lifestyle service; and/or
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
where we need to do in order to comply with a legal or regulatory obligation; and/or we have your consent to the relevant processing.
3.2 We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. We may, however, rely on consent as a condition for processing Special Category Data.
3.3 Note that we may process your personal data for more than one “lawful basis” depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal bases we are relying on to process your personal data where more than one ground has been set out in the table below.
3.4 The specific purposes for which we use your personal data are set out in Section 4 below. We will only use your personal data for the specified purposes for which it was originally collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
3.5 If you would like us to explain how the processing for the new purpose is compatible with the original purpose, please contact us.
5.6 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the principles set out in this Privacy Notice, where this is required or permitted by law.
4. HOW WE USE YOUR PERSONAL DATA
4.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
4.6 We may process data about your use of our website (“usage data“) and Google Ads. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for our processing of usage data is our legitimate interests, namely the proper administration of our website and business.
4.7 We may process information contained in any enquiry you submit to us regarding services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
4.8 We may process information that you provide to us for the purpose of subscribing to our newsletter (“notification data“). The notification data may be processed for the purposes of sending you the relevant newsletter. The legal basis for this processing is consent.
4.9 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
4.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
5. PROVIDING YOUR PERSONAL DATA TO OTHERS
5.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
5.3 We sometimes use third party vendors or suppliers to carry out certain activities, such as processing and sorting data, monitoring usage of our website, management of IT servers and payroll software maintenance. In such cases, we may share your contact details, sale data and other relevant information. Our partner companies must abide by our data privacy and security requirements, and are not allowed to use personal data they receive from us for any other purpose.
5.4 In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. WHY WE PROCESS YOUR INFORMATION
6.1 There are several grounds on which we may collect and use your data, depending on your relationship with us.
6.2 Because you have agreed. Where possible, we collect information about you with your consent. This is the case, for instance, when you sign up for our service.
6.3 Initial registration and set-up of service. In order to register you as a new user of the Jet Setters Lifestyle service, we need to access and process identification data, contact data, profile data and special category data.
6.4 In order to process your membership application, we need to access and use identification data, contact data, profile data, marketing and communications data, and special category data. The relevant lawful bases are
the performance of our contract with you,
the processing is necessary for our legitimate interests (in order to provide a personalised service) and
(in the case of Special Category Data specifically) your consent.
6.5 In order to notify you about changes to our terms and conditions or to this privacy notice, we need to access and use identity data, contact data, profile data, usage data, and marketing and communications data. The relevant lawful bases are
the performance of our contract with you,
the processing is necessary to comply with a legal obligation,
the processing is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, and to develop and grow our business) and
(in the case of special category data specifically) your consent.
6.6 In order to undertake troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, we need to access and use identity data, contact data, technical data and profile data. The relevant lawful bases are
the processing is necessary for our legitimate interests (for running our business, provision of administration and it services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and
the processing is necessary to comply with a legal obligation.
6.7 Because we need it to execute or take steps to enter into a contract with you. If you are one of our customers, we collect or use your personal data because it is necessary for the performance of a contract you are a party to, for instance to deliver goods you have ordered. We may also collect your information because you requested us to take steps prior to entering into a contract with us, for instance when you ask us to give you a quote.
6.8 Because it is in our legitimate interest. We also sometimes process your information in pursuit of our legitimate interests to: carry out direct marketing activities and send you communications in that regard; improve our business and operate it efficiently; prevent fraud; and ensure general safety and security.
When we process your information on that basis, we always make sure that we balance our interest in having the information with your rights and reasonable expectations.
6.9 Because we need it to comply with the law. In some very rare cases, we will need to retain your information because we are compelled to do so by law.
7. RETAINING AND DELETING PERSONAL DATA
7.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 In some cases it may not always be possible for us to specify in advance the periods for which your personal data will be retained however we will determine the period of retention based on the following criteria:
(a) we will retain enquiry data following a data subject’s enquiry submitted to us. In circumstances where the data subject (or their business) has not become a customer of ours we would retain the enquiry data for our future reference for a period of five years;
(b) we will retain notification data for the purposes of facilitating the distribution of our sms notification/newsletter to you for as long as you have consented to receive such communications; and
(c) the period of retention of correspondence data will be determined based on whether there is an ongoing relationship as a result of the initial enquiry and on our assessment of whether we may need that data to comply with our legal obligations or for our legitimate business interests.
7.4 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. YOUR RIGHTS
8.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
9. CONTACT DETAILS
9.1 You can contact us by email if you have any questions or concerns about personal data and privacy matters, using the following contact details:
Please include the words data privacy request in the subject line of your email.
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.