Privacy Policy

1. Who we are

Jetique Circle ("Jetique Circle", "we", "us") operates the flight-club platform available at jetiquecircle.com. Jetique Circle is the data controller responsible for the personal data described in this policy. For any privacy matter you can contact us at privacy@jetiquecircle.com.

2. The personal data we collect

We collect the following categories of personal data:

• Account data: name, email address and password (stored only as a salted hash).
• Contact and identity data: phone number, country, date of birth and fiscal code / tax ID, where you choose to provide them.
• Travel documents: passport or ID scans you upload to your profile.
• Preferences: your Member Passport interests and flight preferences (routes, periods, travel type, notification choices).
• Booking data: the flights, empty legs, shared seats and charter requests you submit, including dates, passenger counts and any notes.
• Communications: emails we exchange with you and the delivery status of transactional emails.
• Technical and usage data: IP address, device and browser type and, only with your consent, analytics data collected via Microsoft Clarity as described in our Cookie Policy.

3. How and why we use your data (legal bases)

Under the EU/UK General Data Protection Regulation (GDPR) we rely on the following legal bases:

• To create and manage your account and provide the platform — performance of a contract (Art. 6(1)(b)).
• To process and fulfil your booking, charter and empty-leg requests — performance of a contract.
• To send transactional emails (registration confirmation, booking updates, reminders) — performance of a contract and our legitimate interest in keeping you informed (Art. 6(1)(f)).
• To send you matching-flight notifications you opted into, and to run analytics — your consent (Art. 6(1)(a)), which you can withdraw at any time.
• To meet accounting, tax and other legal obligations — compliance with a legal obligation (Art. 6(1)(c)).
• To keep the platform secure and prevent abuse — our legitimate interest.

4. Cookies and analytics

We use strictly necessary cookies and local storage to keep you signed in, remember your theme and store your consent choice. With your explicit consent we also load Microsoft Clarity, a privacy-focused analytics tool, to understand how the site is used. You can accept, reject or change this at any time from the "Cookie settings" link in the footer. Full details are in our Cookie Policy.

5. Who we share data with

We do not sell your personal data. We share it only with the service providers (processors) needed to run the platform, and with flight operators and brokers strictly to fulfil a booking you have requested. Our processors include:

• IONOS — cloud hosting and database (European Union).
• Vercel — frontend application hosting.
• Resend — transactional email delivery.
• Microsoft Clarity — website analytics (only with your consent).
• Cloudflare — DNS, security and content delivery.

6. International data transfers

Our core infrastructure and database are located within the European Union. Some processors (such as Resend and Microsoft) may process data outside the EU/EEA. Where that happens, the transfer is protected by appropriate safeguards such as the European Commission’s Standard Contractual Clauses or an equivalent adequacy mechanism.

7. How long we keep your data

We keep your account data for as long as your account is active. When you delete your account we erase your personal data and related records (passport, documents, bookings and lead submissions), except where we must retain certain information to comply with legal, tax or accounting obligations under Italian and EU law. Uploaded documents can be deleted individually from your profile at any time.

8. How we protect your data

Passwords are hashed with bcrypt and never stored in plain text. Data is transmitted over encrypted TLS connections and stored on access-controlled infrastructure. Access to personal data is limited to authorised personnel who need it to operate the service.

9. Your rights under the GDPR

If you are in the EU/EEA or UK, you have the right to:

• Access the personal data we hold about you, and obtain a copy — available instantly from "Download my data" in your profile.
• Rectify inaccurate data and complete incomplete data.
• Erase your data ("right to be forgotten") — available from "Delete my account" in your profile, or by emailing privacy@jetiquecircle.com.
• Restrict or object to certain processing.
• Data portability — receive your data in a structured, machine-readable format.
• Withdraw consent at any time, without affecting processing already carried out.
• Lodge a complaint with your supervisory authority — in Italy, the Garante per la protezione dei dati personali (garanteprivacy.it).

10. Your rights under US privacy laws (CCPA/CPRA)

If you are a California resident (or a resident of a US state with comparable privacy law), you have the right to know what personal information we collect and why, to access and delete it, to correct it, and to opt out of the "sale" or "sharing" of personal information. We do not sell or share your personal information as those terms are defined under the CCPA/CPRA, and we do not use it for cross-context behavioural advertising. We will not discriminate against you for exercising these rights. To exercise them, use the tools in your profile or contact privacy@jetiquecircle.com; we will verify your request against your account.

11. Children

The platform is intended for adults. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. Material changes will be reflected here with a new "last updated" date and, where appropriate, communicated to you. If we change how we use cookies or analytics, we will ask for your consent again.

13. Contact

For any privacy question or to exercise your rights, write to privacy@jetiquecircle.com.