Privacy Policy

1.1. Definition of Personal Data

Under the PDPO, "Personal Data" refers to any data relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.

1.2. Definition of Usage Data

"Usage Data" refers to data collected automatically from your interactions with our website (jetcentrum.com), web applications, or mobile apps, such as IP addresses, browser types, device identifiers, diagnostic logs, and session durations.

1.3. Mandatory vs. Voluntary Supply of Data

When requesting air charter brokering services or submitting passenger manifests, providing information such as passenger names, passport details, date of birth, and visa documents is obligatory to comply with civil aviation security, border control, and customs regulations. Failure to provide mandatory data will result in Jet Centrum being unable to arrange charter flights or process bookings. Providing preferences (such as catering or seating preferences) is voluntary.

1.4. Governing Law

This Privacy Policy shall be governed in all respects by the laws of Hong Kong SAR, without prejudice to mandatory rights granted under applicable international data protection regulations.

2.1. How We Collect Personal Data

• •Flight Inquiries & Bookings — requests for on-demand charters, group charters, empty leg flights, corporate charters, or medical evacuations (Air Ambulance).
• •Passenger Manifests — passports, visa documentation, and security clearance data required by civil aviation authorities and border control.
• •Direct Interactions — meetings, telephone calls (which may be recorded for quality and compliance), and email correspondence.
• •Account Registration — client portal profiles, Jet Card programs, or aviation credit accounts.
• •Third-Party Bookings — when a primary booking contact provides passenger manifest details on your behalf.
• •Automated Technologies — website, mobile application, or third-party authentication logins.

2.2. Third-Party Authentication

If you register or log in using external authentication services (e.g., Apple Sign-In, Google Sign-In), we receive identity verification data (such as name and email address) as permitted by your privacy settings with those platforms.

2.3. Mobile App Permissions & Device Features

When using the Jet Centrum mobile application, we may request device permissions:

• •Location Data — to calculate nearest private jet airports and tailor charter availability.
• •Contacts — to streamline passenger manifest entry when booking for guests.

You can manage or revoke permissions anytime via your mobile device settings.

2.4. Sensitive Data (Medical & Health Information)

Where necessary for flight safety or logistics — such as arranging Air Ambulance services, specialized inflight catering, or accessibility accommodations — we process health data strictly with your explicit consent and share it only with authorized operators, ground handlers, and medical staff directly involved in the flight.

3.1. Primary Operational Purposes

Jet Centrum collects, uses, and discloses Personal Data for:

• •Charter Brokering Operations — coordinating flight requests with certified aircraft operators, ground handlers, fixed-base operators (FBOs), permit providers, and civil aviation authorities.
• •Customs & Border Control — fulfilling border control, immigration, customs, and aviation security requirements.
• •Payment Processing — account billing, credit evaluation, and processing flight deposits or Jet Card transactions.
• •Service Personalization — catering preferences, preferred tail numbers, pet transport requirements, and concierge services.
• •Compliance & Legal — performing Know Your Customer (KYC), Anti-Money Laundering (AML), and sanction list screenings.

3.2. Data Disclosures to Third Parties

To fulfill charter contracts, Jet Centrum may share necessary Personal Data with:

• •Direct Air Carriers / Aircraft Operators operating the charter flight.
• •Fixed-Base Operators (FBOs), ground handling teams, and catering vendors.
• •Airport operators, customs, border protection, and immigration agencies.
• •Payment processing networks, banks, and fraud-prevention providers.
• •Legal counsel, insurance providers, and regulatory auditors under strict confidentiality obligations.

3.3. Direct Marketing

In accordance with the PDPO, Jet Centrum will not use your Personal Data for direct marketing purposes (such as sending charter flight promotions, empty leg updates, or Jet Card offers) unless we have obtained your prior explicit consent (or indication of no objection). You may opt out of receiving direct marketing communications at any time free of charge by clicking "Unsubscribe" in our communications or contacting our Data Protection Officer.

3.4. Non-Sale of Data

Jet Centrum does not sell, rent, or lease your Personal Data to third parties, data brokers, or external advertisers under any circumstances.

Due to the global nature of air charter brokering, your Personal Data (including passenger manifests, passport copies, and flight itineraries) will frequently be transferred to, stored, and processed in foreign jurisdictions where your flight originates, transits, or lands.

Jet Centrum ensures that cross-border data transfers comply with the guidance and Recommended Model Contractual Clauses issued by the Hong Kong Privacy Commissioner for Personal Data (PCPD), ensuring receiving parties maintain data protection standards comparable to the PDPO.

5.1. Security Measures (DPP 4)

We implement physical, technical, and organizational measures — including end-to-end encryption protocols, firewall protection, and restricted access controls — to safeguard your Personal Data against unauthorized or accidental access, processing, erasure, or loss.

5.2. Data Retention (DPP 2)

Personal Data is retained only as long as necessary to fulfill the operational purposes for which it was collected, satisfy accounting/tax requirements, or comply with statutory aviation record-keeping mandates. When no longer required, data is securely destroyed or anonymized in accordance with Section 26 of the PDPO.

Under the PDPO, you have the right to:

• •Check whether Jet Centrum holds your Personal Data and request access to such data (Data Access Request).
• •Request corrections to any inaccurate or incomplete Personal Data (Data Correction Request).
• •Withdraw consent for marketing communications at any time.

In accordance with Section 19 of the PDPO, Jet Centrum will respond to Data Access Requests within 40 calendar days of receipt. We reserve the right to charge a reasonable fee for processing data access requests as permitted under Section 28 of the PDPO.

7.1. Web & Mobile Tracking

jetcentrum.com utilizes essential, functional, and performance cookies along with analytics SDKs to evaluate platform usage, monitor service health, and improve user experience.

7.2. Analytics Tools

We use analytics services (such as Google Analytics) and mobile crash-reporting utilities (e.g., Firebase) to collect aggregated, non-personally identifiable diagnostic logs. You may manage or opt out of browser analytics using browser settings or cookie preferences.