Privacy Policy

1. Introduction.

 

1.1. About This Policy: This Privacy Policy explains how IONA JETS - Dimitri Memleb, trading as IONA JETS ("We", "Us", "Our"), collects, uses, shares, and protects the personal information of users ("You", "Your") of our website (ionajets.com) and the IONA JETS Portal (collectively, the "Platform") and related services. Our primary service is acting as an intermediary, connecting Clients seeking air charter services with third-party Partner Brokers. This Policy outlines our practices in compliance with applicable data protection laws, including the Swiss Federal Act on Data Protection (FADP - nLPD), the EU General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), the California Consumer Privacy Act (CCPA), and other relevant global regulations.

1.2. Scope: This Policy applies to information collected through our Platform, when You [as a User or Client] submit a flight request, register an account if applicable, communicate with us via email or other channels, or interact with our content. It does not cover the data processing practices of the independent Partner Brokers or the ultimate Aircraft Operators, who process Your data under their own privacy policies once You engage with them. This Policy may also generally apply to the personal data of individuals acting in a professional capacity on behalf of our Partner Brokers or other business contacts, to the extent not superseded by specific contractual agreements (such as our Partner Onboarding Agreement).

1.3. Policy Updates: We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. We will post the updated version on this page with a new "Last Updated" date. For significant changes, we may provide a more prominent notice on our Platform. We encourage You to review this Policy periodically.

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2. Information We Collect.

2.1. Information You Provide Directly: We collect information You provide directly to us. This includes contact and identification information, such as Your name, email address, and phone number, which You provide when You contact us or submit a request. Additionally, we collect flight request details You provide, which encompass information like Your desired itinerary including origin, destination, dates, and times, the number of passengers, any specific requirements, and potentially passenger names or categories if relevant for initial quoting purposes. When You submit flight requests through forms on our website (ionajets.com), this information is processed and stored in our flight request management system (utilizing services from Formagrid, Inc., provider of Airtable). If You create or use an account on the IONA JETS Portal (which is built using services from Softr, Inc.), we will collect account registration details You provide, such as Your chosen username and contact information. IONA JETS does not have access to or store Your password for the IONA JETS Portal; password management and security are handled by the Softr platform's authentication system. Finally, we keep records of communications You have with us.

2.2. Information Collected Automatically: We automatically collect certain information when You access and use the Platform. This usage data includes Your IP address, browser type, device type, operating system, the pages You viewed, the time spent on those pages, the links You clicked, and referring website addresses. We use cookies and similar tracking technologies, such as web beacons, to collect this usage data, enhance Your user experience, and analyze Platform traffic, as further detailed in Section 8 regarding Cookies.

2.3. Information from Third Parties: Generally, we do not receive personal information about You from third parties, with the potential exception of aggregated or anonymized data provided by analytics providers.

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3. How We Use Your Information and Legal Bases.

We use Your personal information for several purposes, relying on specific legal bases as required by laws like GDPR, FADP, and UK GDPR. Primarily, to facilitate Your flight requests, which is our core service, we use Your contact information and flight request details; the legal basis for this is the performance of a contract or taking pre-contractual steps at Your request, enabling Partner Brokers to provide quotes. For providing and managing the Platform itself, including account features if applicable, we use contact information, account information, and usage data, based on the performance of a contract and our legitimate interests in operating the Platform securely and efficiently. To communicate with You, responding to Your requests and inquiries or providing service updates, we use contact information, communications records, and request details, based on performing a contract, taking pre-contractual steps, or our legitimate interests. To improve Our Platform and Services, we analyze usage data, cookie data, and anonymized or aggregated data, relying on our legitimate interests to understand user behaviour and enhance the user experience. If You choose to receive marketing communications, we use Your contact information based on Your explicit consent, which You can withdraw at any time. Finally, we may use any relevant information to comply with legal obligations or protect our rights, property, or safety, and that of others, based on legal obligation or legitimate interests.

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4. Sharing Your Information.

 

We do not sell Your personal information in the traditional sense. However, sharing Your information is necessary for our operations and to provide Our Services to You. We may share Your personal information in the following circumstances:

4.1. With Third-Party Service Providers (Data Processors): We engage third-party service providers to support the operation of our Platform and the provision of Our Services. These providers act as data processors on Our behalf, are contractually obligated to protect Your information, and use it only for the services they provide to Us. We have entered into data processing agreements (DPAs) with these service providers where required by applicable law. Our key service providers include: a) Website Hosting: Wix.com Ltd. (based in Israel, with global server infrastructure) for hosting Our primary website, ionajets.com; b) IONA JETS Portal Operation: Softr, Inc. (based in the USA) for building, hosting, and operating the IONA JETS Portal. This includes managing user authentication (including usernames and password security, to which IONA JETS does not have access) and facilitating Client flight request management and Partner proposal submissions; c) Database Management: Formagrid, Inc. (provider of Airtable, based in the USA) for storing and managing data related to flight requests, Client details, and Partner information processed via Our Platform; d) Analytics: Potential analytics providers like Google Analytics (based in the USA) to help Us understand Platform usage and improve Our Services, subject to Your consent where applicable; e) Communication Tools: Providers of email services for communication with You and Partner Brokers; f) Customer Support Tools: Retell AI, Inc. (based in the USA) for managing and processing client communications via our telephone support line.

4.2. With Partner Brokers: Essential to Our core service, we share Your contact information and flight request details with one or more relevant Partner Brokers in Our network. This allows them to evaluate Your request and potentially contact You directly with a Quote and their terms. These Partner Brokers act as independent controllers of Your data for their brokerage services and will process Your information according to their own privacy policies. We encourage You to review their privacy policies.

4.3. For Legal Reasons or Business Transfers: We may disclose Your information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to investigate illegal activities, enforce our agreements, defend against claims, protect the security of our Service, or protect the rights and safety of IONA JETS, our users, or others. Lastly, in the event of a business transfer such as a merger, acquisition, reorganization, or sale of assets, Your information may be transferred as part of that transaction.

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5. International Data Transfers.

 

5.1 Your personal information may be transferred to, stored, and processed in countries other than Your country of residence, where data protection laws may differ. Specifically: a) Our website hosting provider, Wix.com Ltd., is based in Israel, which is recognized by Switzerland and the European Commission as providing an adequate level of data protection for personal data transfers from these regions; b) Our IONA JETS Portal provider, Softr, Inc., our database provider, Formagrid, Inc. (AirTable), RetellAI and potentially other service providers such as analytics or communication tool providers are primarily based in the United States. Consequently, personal data processed through the Portal, stored in our database, or handled by these services may be transferred to the USA; c) Our Partner Brokers may be located worldwide.

5.2 When we transfer Your personal data to countries outside of Switzerland, the European Economic Area (EEA), or the UK that are not deemed to provide an adequate level of data protection (such as the United States for certain services), we implement appropriate safeguards to protect Your personal data. These safeguards primarily include the use of Standard Contractual Clauses (SCCs) approved by the European Commission and adapted as necessary for Swiss and UK requirements, or other recognized legal transfer mechanisms as permitted by applicable law. By using Our Platform and submitting Your information, You acknowledge and consent to these potential international transfers, which are conducted with appropriate safeguards in place.

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6. Data Retention.

We retain Your personal information only for as long as reasonably necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. The criteria determining our retention periods include the duration needed to provide our intermediary services to You, such as processing Your request; the duration Your account remains active, if applicable; our legal and regulatory obligations, for instance, the typical 10-year retention period for commercial documents under Swiss law; the necessity to resolve disputes or enforce our agreements. Data related to specific requests that do not result in a booking may be retained for a shorter period for analytical or operational purposes before being anonymized or deleted.

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7. Data Security.

 

We implement appropriate technical and organizational security measures designed to protect Your personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include techniques like encryption, access controls, and the use of secure hosting environments. However, it is important to understand that no method of transmission over the Internet or electronic storage is 100% secure, and therefore we cannot guarantee absolute security. You also play a role in protecting Your information by keeping any account passwords confidential. For accounts on the IONA JETS Portal, You are responsible for choosing a strong password and keeping it confidential; as IONA JETS does not have access to Your Portal password, it is Your responsibility to manage its security.

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8. Cookies and Similar Technologies.

8.1. Use of Cookies: We use cookies, which are small text files stored on your device, and similar technologies like pixels or web beacons. These technologies help us operate the Platform, collect Usage Data, remember Your preferences, manage sessions, and potentially conduct analytics and marketing activities, subject to Your consent where required.

8.2. Types of Cookies Used: The cookies we may use fall into several categories. Strictly Necessary Cookies are essential for the Platform to function correctly, handling tasks like security, network management, and basic site navigation, and cannot be disabled. Functional Cookies allow the Platform to remember choices You make, such as language preference, to provide a more personalized experience. This may include cookies set by components of the IONA JETS Portal (operated via Softr) to ensure its proper functioning and remember user sessions or preferences within the Portal. Analytics Cookies help us understand how visitors interact with the Platform, for example, by identifying popular pages or tracking errors, enabling us to improve our services; Google Analytics, if used, falls into this category. The IONA JETS Portal or other integrated services may also utilize cookies for analytics purposes to help us understand their specific usage, subject to Your consent choices. Marketing Cookies might be used to track browsing habits to deliver more relevant advertising, although this is less likely for our current service model.

8.3. Managing Cookies: We provide a cookie consent management tool, likely through Wix or a similar service, which allows You to manage Your preferences for non-essential cookies. Additionally, You can typically control cookies through Your web browser settings. Please be aware that disabling certain cookies may impact the functionality of the Platform.

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9. Your Data Protection Rights.

Depending on Your location and the applicable data protection law, You may possess several rights regarding Your personal information. These rights can include the Right to Access a copy of the information we hold about You, the Right to Rectification to correct inaccurate or incomplete information, and the Right to Erasure, also known as the 'Right to be Forgotten', allowing You to request deletion of Your information under certain conditions. You might also have the Right to Restrict Processing, limiting how we use Your information under specific circumstances, and the Right to Data Portability, enabling You to request Your information in a structured, machine-readable format and potentially transfer it elsewhere, again under certain conditions. Furthermore, You may have the Right to Object to processing based on our legitimate interests or for direct marketing, and the Right to Withdraw Consent at any time if processing is based on consent, though withdrawal does not affect past processing. You also generally have Rights Related to Automated Decision-Making, ensuring You are not subject to decisions based solely on automated processing that produce significant effects on You; we currently do not engage in such processing. Finally, under laws like the CCPA, You have the Right to Non-Discrimination for exercising Your privacy rights.

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10. Specific Information for California Residents (CCPA) & Your Choices Regarding Information Sharing.

 

This section provides additional details primarily for residents of California in compliance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). IONA JETS aims to extend principles of transparency and control over personal information to all Our users where feasible.

10.1. Your Rights (Including under CCPA/CPRA): Depending on Your location and applicable law, You may have certain rights regarding Your personal information. For California residents, these include: a) Right to Know/Access: You have the right to request that We disclose to You the personal information We collect, use, disclose, and potentially sell or share. This includes the categories and specific pieces of personal information, the categories of sources from which it was collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom We disclose, sell, or share it. This typically covers the 12-month period preceding Your request; b) Right to Delete: You have the right to request the deletion of Your personal information that We have collected from You, subject to certain legal exceptions (e.g., if the information is necessary to complete a transaction You requested, to comply with a legal obligation, or for certain other internal uses); c) Right to Correct: You have the right to request the correction of inaccurate personal information that We maintain about You; d) Right to Opt-Out of Sale/Sharing: You have the right to direct Us not to "sell" or "share" Your personal information. Under the CCPA/CPRA, "sell" is broadly defined to include making personal information available to a third party for monetary or other valuable consideration. "Share" is broadly defined to include making personal information available to a third party for cross-context behavioral advertising. For IONA JETS, the primary activity that could potentially fall under these broad definitions is the "sharing" of Your flight request details (which includes Contact Information and Flight Request Details) with Our network of Partner Brokers. We do this to obtain quotes for You, and We may receive a commission if a Service Contract is concluded. We do not "sell" personal information in the traditional sense of exchanging it for direct monetary payment with data brokers, nor do We "share" it for cross-context behavioral advertising purposes as currently defined by the CCPA/CPRA; e) Right to Limit Use and Disclosure of Sensitive Personal Information (SPI): If We collect SPI, You have the right to direct Us to limit Our use and disclosure of Your SPI to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer requesting those goods or services, or as otherwise permitted by regulations; f) Right to Non-Discrimination: We will not discriminate against You for exercising any of Your applicable privacy rights.

10.2. How to Express Your General Preference to Opt-Out of Future Sale/Sharing: You may express a general preference to limit the future sharing of Your personal information with Our Partner Brokers (which, as explained above, could be considered a "sale" or "sharing" under CCPA/CPRA definitions): a) You may click on the "Do Not Sell My Personal Information" link, which is accessible at the bottom of this Privacy Policy page; b) Clicking this link will present a pop-up. To confirm Your general preference, click the "Submit" button within this pop-up. Please be aware that this preference is typically managed via browser-based mechanisms (e.g., cookies provided by Our website platform, Wix.com Ltd.) and its persistence may be affected by Your browser settings, clearing cookies, or using different devices/browsers. Upon clicking "Submit" in the pop-up, Our website platform will indicate "Your data will not be transferred to any 3rd party"; this refers to the general preference being set for future contexts within the limitations of such browser-based tools; c) For a more persistent record of Your general opt-out preference, or if You encounter any issues, We encourage You to also submit Your request by emailing Us at contact@ionajetscharter.com with the subject line "Opt-Out of Sale/Sharing Preference". Please include sufficient information for Us to identify You (e.g., name and email address).

10.3. Submitting a Specific Flight Request and Its Relation to Your Opt-Out Preferences: Our core service is to connect You with Partner Brokers to obtain flight quotes. This fundamentally requires Us to share the details You provide in a flight request form with these Partner Brokers. If You complete and submit a flight request form on Our Platform, Your action of submitting that specific request will be understood as Your direct instruction and explicit consent for Us to share the information contained within that particular flight request with relevant Partner Brokers for the purpose of obtaining quotes for You for that specific flight. This sharing is essential for Us to provide the requested service. This specific instruction for a given flight request will take precedence over a previously expressed general opt-out preference, but only for the processing of that individual request. Your general opt-out preference, if previously submitted, will otherwise remain in effect for other contexts or future data processing not directly initiated by a new service request from You that explicitly involves such sharing. If You have expressed a general opt-out preference and do not wish for a specific new flight request to be shared with Partner Brokers, You should refrain from submitting that request through Our standard online forms. You may contact Us to discuss Your needs, though Our ability to obtain quotes without sharing Your request details will be severely limited or impossible.

10.4. California's "Shine the Light" Law: California Civil Code Section § 1798.83 (the "Shine the Light" law) permits users of Our Platform that are California residents to request certain information once a year regarding Our disclosure (if any) of personal information to third parties for their own direct marketing purposes in the preceding calendar year. IONA JETS does not currently share personal information with third parties for their own direct marketing purposes in a manner that would trigger this requirement without appropriate consent or as permitted by law.

10.5. Authorized Agent: You may designate an authorized agent to make a request under the CCPA/CPRA on Your behalf. We will require verifiable written proof of the agent's authorization to act on Your behalf and may also need to verify Your identity directly before processing the agent's request, as permitted by law.

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11. Exercising Your Rights & Contact Information.

 

11.1. How to Exercise Your Data Protection Rights:

11.1.1. To exercise any of Your data protection rights as described in this Privacy Policy (including those under GDPR, FADP - nLPD, UK GDPR, CCPA/CPRA, or other applicable laws), or if You have any questions or concerns regarding this Privacy Policy or Our data practices, please contact Us. You can reach Us by: a) Email: contact@ionajetscharter.com; b) Postal Mail: IONA JETS - Dimitri Memleb, Cours des Bastions 13, 1205 Geneva, Switzerland.

11.1.2. Please specify Your request clearly and provide sufficient information to allow Us to identify You and understand the nature of Your request. We will respond to Your request in accordance with applicable law, typically within one month of receipt, or as otherwise required or permitted by law (e.g., an extension of up to two additional months may be necessary for complex requests, in which case We will inform You). Please note that We will need to verify Your identity before processing Your request to protect Your personal information from unauthorized access or alteration. The extent of verification will depend on the sensitivity of the information and the risk of harm from unauthorized access or deletion.

11.2. Complaints: If You are unsatisfied with Our response to Your request or believe that We are processing Your personal information unlawfully, You have the right to lodge a complaint with the competent data protection authority. We would, however, appreciate the chance to address Your concerns before You approach a supervisory authority, so please contact Us in the first instance. The competent authorities are generally as follows: a) In Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC), accessible via https://www.edoeb.admin.ch; b) Within the European Union / European Economic Area (EU/EEA), You should contact the data protection authority in Your EU/EEA country of habitual residence, place of work, or place of the alleged infringement. A list of EU/EEA data protection authorities is available on the European Data Protection Board (EDPB) website; c) In the United Kingdom (UK), the relevant authority is the Information Commissioner's Office (ICO), accessible at https://ico.org.uk; d) For California residents, complaints can be directed to the California Privacy Protection Agency (CPPA) via https://cppa.ca.gov/.

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Last updated: May 21, 2025.