Privacy Policy

Updated March 7th, 2018

 

This privacy policy governs the way Tuki Jets ltd, a company incorporated under the laws of the State of Israel, P.C.N 515919181 (hereinafter, the “Company”) collects, uses, maintains and discloses your information in www.ImperiumJets.com, the “ImperiumJets  Platform”, when you use it.

Acceptance of this Policy

By using the ImperiumJets Platform, you accept this policy and terms of use which are an inseparable part hereof. If you do not agree to this policy, please do not use the ImperiumJets Platform.

Changes to this Statement

We periodically update this privacy policy to take account of changes to our operations or practices, and further, to make sure it remains appropriate to any changes in law, technology and the business environment. When we do, we will also revise the “updated” date at the top of this privacy page. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy policy and to its updates.

Our platform connects empty aircraft flights with travelers. The ImperiumJets Platform consolidates available flights from charter aircraft companies (“Flight Operators”, and provides that information to you, for your bookings. The ImperiumJets Platform is assimilating a customized and combined search in the available inventory of aircraft flights.

Your Data Controller

We, the Company, are your data controller, and are responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Policy, as well as any applicable national laws. The Company uses cloud hosting services (AWS or others), implementing best practices for keeping your information secured. All communications between the ImperiumJets platform and our servers is secured under SSL protocol, to make sure no information is viewed or accessed by unwanted parties.

Where we have a legal obligation to do so, we have appointed data protection officers (DPOs) to be responsible for the Company’s privacy program for the respective data controllers. If you have any questions about how we protect or use your personal information, you can contact our DPOs by email at support@tukijets.com

What kinds of information is being collected by us?

We collect different kinds of information from or about you.

Things You Do and Information You Provide.

In general, we will collect any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

In order to provide you with the best of services, when you use our services, we collect all the information you provide, including but not limited to your passport details, home address, birthdate, and information you submit when you sign up for an account, all emails sent to us, and all message or communications – including the content of the messages.

Also, to optimize our services to you, we collect information about the way you use our services. For example, we record the types of content you view, what do you engage with, or the frequency and duration of such or similar activities.

For security and verification purposes, we may also retain your I.D card scan or photo, including your passport’s full scan or photo. We collect your age, nationality, address, and gender to be provided to us by you as part of the the Tuki Platform services, and other personal identifiable information.

Technical Information Provided by Your Device.

We always strive to optimize our platform and services, fix bugs and make our software better. Therefore, when you use your computer, phone, tablet or any other device on which you run the Tuki Platform, we collect information from or about the device itself. We will combine the information about your account to give us a better understanding of your use of services, so we can provide you with better and customized services.

To make the service tailored just for you, among other information, we collect the device’s geographic locations, and we retain all information which was sent to the Tuki Platform, including by Wifi, GPS or other means.

As part of our continuous optimization process, we collect the type and version of the device’s operating system, and other device information such as internet service provider, languages set on the Tuki Platform, time zones, mobile operator, phone number and I.P address being used to access the Tuki Platform.

Information From Third-Party Service Providers.

When you are being directed to the Tuki Platform from third-parties, we receive information about you and your activities from such third-parties, which is similar to the information we collect on the Tuki Platform.

Information About Payments

When you are being directed to the ImperiumJets Platform from third-parties, we receive information about you and your activities from such third-parties, which is similar to the information we collect on the ImperiumJets Platform.

Cookies

Cookies are small data files stored on your hard drive or in a device memory, which helps us to improve the ImperiumJets Platform and your experience. To provide efficient and smooth services to you, we use cookies and also similar technologies to provide and support the ImperiumJets Platform, and to protect and improve them, such as by personalizing content, tailoring and measuring ads, authenticate users and prevent fraudulent use of user accounts, remember information that changes the way the ImperiumJets Platform behaves or looks (such as user language and functionality), track information about how the ImperiumJets Platform is used so that we can make improvements, etc. We may also use analytics cookies to test new advertisements, pages, features or new functionality of a particular service to see how our users react to them. We also use cookies to see which areas and features of the ImperiumJets Platform are popular, and count visits.

This may include sending and reading cookies from your computer or mobile device.

Information We Collect From Other Sources.

We may obtain information from other third-parties and combine it with information we collect through the ImperiumJets Platform. For example, if you log into your account through a social media site, you will automatically grant us access to certain information on you which is stored on that site, such as your name, account information, friends lists, etc.

AFTER YOU MAKE A PURCHASE ON THE IMPERIUMJETS PLATFORM, WE MAKE GENERAL BACKGROUND CHECKS ON YOU. WE CHECK CRIMINAL RECORDS, PERSONAL STATUS AND FINANCIAL STATUS IN ORDER TO PROTECT OTHER PASSENGERS ON FLIGHTS. SUCH INFORMATION IS BEING DELIVERED TO FLIGHT OPERATORS.

How do we use the information we collect?

We use the information in the following ways:

Providing the services and customizing your user experience.

We will use the collected information to provide, optimize, personalize and customize the services for you. For example, we might present you with offers, whether the ImperiumJets Platform’s or a third-party’s offer, which is based on the information that we possess about your interests and your location. This can be made on the ImperiumJets Platform, by email or by other means.

We try to show you the most relevant and interesting ads, specifically for you. Therefore, we will show you ads of products or services, and we will measure the impact these ads have upon you. The collected information will be used to improve our advertising and measurement systems, to make the ads more relevant, and to measure the effectiveness of these ads upon you.

We also use the information to respond to you when you contact us, to better understand the issue in question, your request or remark

We will send you confirmations, receipts, technical notices, updates, security alerts, support and administrative emails and/or messages.

For your security, in case your user account has been compromised or a potential security breach has occurred, or in case you’ve lost your credentials or access to the ImperiumJets Platform, we use the information collected to ascertain your identity and give you back the control over the account.

We may also use the collected information for general user security purposes to investigate suspicious activity or potential violations of our terms or policies. We may use the information if we believe your actions are inconsistent with our terms or policies, or to protect the rights, property and safety of the ImperiumJets Platform, its employees, volunteers or others.

Transferring Information to Third-party Partners, Service Providers and Customers.

We work with Flight Operators, with third party companies, and with service providers who help us provide and improve our services to you, or who use advertising or related products with the ImperiumJets Platform. This cooperation allows the ImperiumJets Platform to keep the services free for you and continue to provide worldwide service and support its expansion and development. We share information with such third-party partners and customers for the sake of these purposes.

The transferring of information to third parties may be done in order to provide us with technical services to improve them for your benefit, or it can be used to analyzing how the ImperiumJets Platform is used, facilitating payments, measuring the effectiveness of ads and services, conducting surveys or providing customer service. Third-parties that receive such personal identifiable information MUST follow strict confidentiality obligations presented by us, under the agreements we enter into with such third-parties, and in a way that is consistent with this privacy policy.

Other personal identifiable information such as phone number, will be delivered to Flight Operators subject to applicable law, and is governed by their own privacy policies.

Subject to your explicit consent, information will be transferred to advertising clients (Non-Personally Identifiable Information only) – to tailor-made the ads for you, to present you with as interesting and relevant ads as we can present you with. Our goal is to give you the best services which match your interests. Therefore, and subject to your explicit consent, we will use the information we have on you to tailor you the most relevant ads we can. We will never send to advertising clients any personally identifiable information such as passport copies, names, I.D numbers, credit cards, email address (information that can be used to contact you or which identifies who you are), or any other information that can be used for identity-theft and which can compromise your security in any way.

Sharing your data outside of the EEA

In order to provide our services to you, it is sometimes necessary for us to transfer your data to the third parties that are based outside of the European Economic Area (“EEA“). In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.

By using the ImperiumJets Platform, you consent to your personal data being transferred to other countries, including countries that have different data protection rules than your country. In all such transfers, we will protect your personal information as described in this Privacy Policy. For more information, please contact us at support@tukijets.com.

Legal Requests for Information

In any rare case where we are presented with any legal request about you (court order, a search warrant, etc), we may share your information after examining the governing laws and coming to conclusion that the law requires us to share information as such.

If the response to that legal proceeding or request is required by law, if it affects users or people in that jurisdiction, and if it abides international standards, we may respond in information sharing to such legal proceeding or request if it was made outside the EEA.

Moreover, for the security and safety of users and people in general, we will retain and share any information which by our view is required to: investigate, detect, prevent and handle illegal activity such as fraud or crimes; to prevent physical harm to people, or to protect ourselves, you or others from any harm.

Furthermore, any information you share with us, including data pertaining to transactions made on the ImperiumJets Platform, may be subject to a legal proceedings, request or obligation, wherein information about you will not be deleted even if you request us to do so. Such limitation will also apply to governmental investigation, or investigations by us pertaining to possible violations of our terms or policies.

How do we protect your personal information?

We take reasonable measures to implement security on the ImperiumJets Platform and help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. Measures we take include encryption with SSL and periodic review of our collection of information, its storage and processing practices. We restrict access of your information only to those Company’s employees, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your information from unauthorized access.

Nevertheless, as the communications with the ImperiumJets Platform is done by means of the internet, and as a computer platform, we cannot guarantee that the use of the ImperiumJets Platform or the interaction therewith will be 100% free viruses, worms, Trojans, and all other malware which are otherwise out of our reasonable control.

How can I delete information collected about me?

The information you have shared with us is being retained by us indefinitely, including when your account has been deleted by you or us, unless we have no further use of this information, or unless you have requested us to delete the information.

If you wish to have your information and content deleted from the ImperiumJets Platform’s database, you may submit a request by the means of communications detailed here. We will need to ascertain your identity as the subject of such information and publisher of such content before we can proceed with the deletion of the information and content.

Nevertheless, we will retain information from accounts which have been disabled by us for violations of our terms or policies for a period determined by us from time to time.

Your Choices

  1. Email Communications – Subject to applicable laws and regulations, we may from time to time send communications promoting services, products, facilities, or activities to you using information collected from you. When you create an account, you are agreeing to opt-in to all communications from us. We will provide you with an opportunity to opt-out of newsletter communications. We will never provide your personal information to third parties for direct marketing or other unrelated purposes without your written consent.
  2. Cookies – You may decline session cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of the ImperiumJets Platform.
  3. Right of Rectification– You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.
  4. Right of Erasure – You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which the Company is subject to.

Location Information – You may be able to stop the collection of location information through your device settings; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of the ImperiumJets Platform.

Access to information

Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact support@tukijets.com.

 

The California Consumer Protection Act (“CCPA”)

The following section on CCPA, Cal. Civ. Code § 1798.100 which is effective January 1st, 2020, applies to California residents who have certain rights regarding the personal information (as defined in the CCPA) collected by the Company. It does not cover personal information not subject to the CCPA rights identified below, such as personal information we collect from our employees or job applicants. Likewise, the CCPA does not extend all the rights identified below to personal information collected from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

Definitions

  1. Personal information” or “PI” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
  2. Consumer” is a California resident, a natural person who is a California resident for other than a temporary or transitory purposes, or someone who is domiciled in California but is currently outside California for a temporary or transitory purpose.
  3. Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the Company to another business or a third party for monetary or other valuable consideration.

California residents have the following rights under CCPA

  1. Right to Opt Out. You have the right, at any time, to direct us to not sell your PI. You can do so on by sending an email to support@tukijets.com.
    1. Sale of PI. Under the CCPA, sale is also broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services.
    2. Categories of PI We Provide. We provide the following categories of information to third parties: including identifiers, geolocation information, professional or employment related data, and physical characteristics or descriptions.
    3. Purpose of the Sale: We may provide the following categories of personal information to third parties for these purposes:
      1. For online targeted advertising purposes: device identifiers (such as browsing history; geolocation information; social media information); and
      2. For sharing with third parties to send you relevant offers and promotions and opportunities, such as when you sign up for an event or to receive more information and provide categories of information to us: identifiers, professional or employment related data (such as your job title or current company), and physical characteristics or descriptions (such as if you provide a picture of yourself).
  1. Right to Know or Right to be Informed. Subject to certain exceptions, you have the right to know what specific pieces of PI the Company has collected about you in the 12 months preceding your request, along with the categories of sources of that PI, our business or commercial purpose for disclosing your PI, and the categories of third parties with whom we share your PI. You may make this request no more than twice per 12-month period.
  2. Right to Request Deletion. You have the right to request deletion of the PI that the Company has collected from you, subject to certain exceptions under the CCPA including, without limitation:
    1. Making sure you can receive services from the Company if you would still like to;
    2. Complying with The Company’s legal or compliance obligations;
    3. Detecting fraudulent behavior or security incidents; and
    4. Other reasons that are in connection with our lawful internal uses that are consistent with your relationship with us and the context in which the information was collected.

Exercising Your Rights under CCPA

You can exercise any of your rights under CCPA by emailing us at support@tukijets.com.

We will take reasonable steps to verify your identity before responding to a request, which may include the following:

  1. If you are exercising your Right to Delete or a similar right that does not require the disclosure of specific pieces of information about you:
    1. If you are writing to us from the email address associated with your Company account that the Company has on file for you, then to complete the verification process, we will ask you to confirm the action you wish us to take before we proceed (such as confirming you would like us to delete your information).
    2. If you are not writing to us from the email address associated with your Company account that the Company has on file for you, then to complete the verification process, we will ask you to provide 3 specific pieces of data that we have on file for you, such as email address you used when logging in or billing information such as the last 4 digits of the credit card used.
  2. If you are exercising your Right to Know or a similar right that does require disclosure of specific pieces of information about you:
    1. If you are writing to us from the email address associated with your Company account that the Company has on file for you, then to complete the verification process, we will ask you to both: 1) confirm the action you wish us to take before we proceed and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made.”
    2. If you are not writing to us from the email address associated with your Company account that the Company has on file for you, then to complete the verification process, we will ask you to both: 1) provide 3 specific pieces of data that we have on file for you, such as email address you used when you log on or billing information such as the last 4 digits of the credit card used, and 2) also provide a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know request has been made.”
  3. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above methods before processing the authorized agent’s request.
  4. If we are not able to successfully verify you according to the above methods, then we will not be able to comply with your request.

The Company will not discriminate against you if you exercise your rights under CCPA. However, if your request requires us to delete, restrict or not share information, please be advised that this will inhibit some functionality of the ImperiumJets Platform. Any subsequent interaction with the Site after deletion will require new requests for action on your data.

Other rights of California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to support@tukijets.com. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your personal information with third parties’ direct marketing use unless you elect that we do so.

If you are a California resident under the age of 18, and a registered user of any website where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please contact us with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even if requested.

 

Contact Us

Any questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to support@tukijets.com.

 

Alternatively, you may contact us here:

Tuki Jets ltd.
121 Dvora Hanevia st.,
Tel Aviv, Israel

If you feel that we have not addressed your questions or concerns adequately, you may one of our DPOs.