Last Updated: July 26, 2024
This Privacy Policy for JetJustice (we, ‘us’, or ‘our’) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (‘Services’) such as when you visit our website or any website of ours that links to this Privacy Policy; and engage with us in other related ways. This Privacy Policy applies to jetjustice.com (the “Website”) owned and operated by JetJustice Limited, a Company Registered in England and Wales, company number 15856420 with its registered address at Analysis House 117-119 Sea Road, Sunderland, England, SR6 9EQ.
This Privacy Policy sets out our complete online practices regarding the collection, use, disclosure, and security of your personal data. It also explains your rights to access and manage your personal data. Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].
JetJustice takes data protection seriously and ensures compliance with various regulations depending on your location. For users in the European Economic Area (EEA) and the UK, JetJustice adheres to the General Data Protection Regulation (GDPR) 2016 and the UK Data Protection Act (DPA) 2018, which grants users rights to access, rectify, erase, and restrict processing of their data. For users in Brazil, we comply with Lei Geral de Proteção de Dados (LGPD), which offers similar data privacy rights. If you are a California resident, the CCPA grants you specific rights regarding your personal data, including the right to know what Personal Data is collected, used, and disclosed, the right to delete your Personal Data, and the right to opt out of the sale of your Personal Data.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
- PROCESSING CLAIMS FOR OTHER PASSENGERS
- COOKIES AND OTHER TRACKING TECHNOLOGIES
- LIMITED AUTOMATED DECISION-MAKING AND NO PROFILING
- HOW LONG DO WE KEEP YOUR INFORMATION?
- DATA SECURITY
- WHAT ARE YOUR PRIVACY RIGHTS?
- KEEPING YOU INFORMED (WITH YOUR CONSENT)
- CONTROLS FOR DO-NOT-TRACK FEATURES
- YOUR RIGHT TO LODGE A COMPLAINT
- CHANGES TO THIS POLICY
- CHANGES TO OWNERSHIP OR CONTROL
- CONTACT US
WHAT INFORMATION DO WE COLLECT?
Personal Data you disclose to us: We collect Personal Data that you voluntarily provide to us when you register on our website, access our services, express an interest in obtaining information about us or our services, or otherwise when you engage with us. The Personal Data that we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. The Personal Data we collect may include your full names, phone number, email address, full mailing address, and photograph(s) of your passport/ID documents. We may also collect flight cancellation information, rebooking details, and details of any expenses you have incurred in relation to the flight disruption. All Personal Data that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Data. This processing will be carried out in accordance with applicable privacy laws and regulations to ensure the confidentiality and security of your personal data.
Payment Data: If your claim is successful and we recover compensation from the Airline on your behalf, we may collect your payment information to facilitate the transfer of funds to you. This information may include your bank account information or details for a secure payment service. We will record basic details about the transaction such as the amount transferred and the date of payment. Once your payment is complete, we will promptly delete all your payment information from our systems. We will only retain the aforementioned transaction information for record-keeping purposes, but this information will not be linked to your personal data.
Information automatically collected: We may also automatically collect certain information when you visit, use, or navigate the Website. This information is aggregated and does not reveal your specific identity (like your name or contact information) but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website, and other technical information. This information is primarily needed to maintain the security and operation of our website and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy available here.
HOW DO WE PROCESS YOUR INFORMATION?
We process your Personal Data in compliance with applicable data privacy regulations for a variety of reasons depending on how you interact with our Services, including without limitation: (i) to facilitate account creation and authentication and otherwise manage user accounts; (ii) to deliver and facilitate delivery of the Services to the user; (iii) to respond to user inquiries/offer support to users; (iv) to send you details about the Services, changes to our terms and policies, and other similar information; (v) to request feedback and to contact you about your use of our Services; (vi) to send you marketing and promotional communications with your consent. We may process the Personal Data you send to us for our marketing purposes if this is in accordance with your marketing preferences and subject at all times to your consent. You may opt out of our marketing and promotional emails at any time; and (vii) to identify usage trends.
In addition to the foregoing, we may use and process your information to comply with our legal obligations, respond to lawful requests or court orders, and enforce our terms and conditions. This includes protecting our rights, safety, and property, as well as the rights, safety, and property of our users or any other third parties. We may aggregate and anonymise your information to create statistical or aggregated data that does not personally identify you. This aggregated and anonymised data may be used for various purposes such as analysing usage patterns, improving our Services, conducting market research, or sharing with third parties for lawful purposes.
LEGAL BASES FOR PROCESSING YOUR INFORMATION
The GDPR requires us to explain the valid legal bases we rely on in order to process your Personal Data. As such, we may rely on the following legal bases to process your Personal Data:
- Contract: In some cases, we process your Personal Data to fulfill our contractual obligations with you. This is the primary legal basis for processing information related to claim processing. When you submit a travel disruption claim, we use your travel information, expense details, and contact details to assess your eligibility for compensation, negotiate with the Airline on your behalf, and recover compensation. This processing is necessary to perform our obligations under the terms of service you agree to when using JetJustice.
- Consent: We may also process your personal data with your explicit consent. This may include marketing communications. We will only send you marketing emails or promotional offers with your prior consent. You can always withdraw your consent by following the unsubscribe instructions in our communications or by contacting us directly.
- Legitimate Interests: In some instances, we may process your Personal Data based on our legitimate interests, provided these interests do not override your fundamental rights and freedoms. Legitimate interests we rely on may include:
- Service Improvement: We may use your usage data to analyse user behavior and improve the functionality and user experience of the Services.
- Fraud Prevention: We may use information to detect and prevent fraudulent claims, unauthorised access attempts, and other malicious activities to protect the security of our platform and our users.
- Analytics and Reporting: We may use your anonymised data for internal analytics and reporting purposes to understand user trends and improve the overall effectiveness of JetJustice.
- Customer Support: We may use your information to provide you with customer support, including troubleshooting technical issues and resolving inquiries.
- Compliance: We may also process your information to comply with applicable laws and regulations, such as responding to court orders, subpoenas, or legal investigations.
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
Airlines: In order to process your travel disruption claim and recover compensation on your behalf, we may be required to share your information with the airline involved in the disruption. This information may include your travel itinerary, rebooking details, incurred expenses, and any other relevant information necessary to support your claim.
Legal and Regulatory Authorities: We may disclose your information to law enforcement agencies, regulatory bodies, consumer protection organisations, law firms or external solicitors, debt collection agencies, or other third parties if we decide to do so in connection with providing the Services or if we believe such disclosure is necessary to comply with a legal obligation, respond to court orders or subpoenas, prevent fraud or other illegal activities, or protect the safety and security of our users or the public.
Service Providers: We may share your personal data with service providers necessary for specific services like website hosting, courier, server maintenance, and email services. We ensure these subcontractors implement appropriate security measures to protect your privacy.
Business Transfers: In the event of a merger, acquisition, or asset sale, your information may be transferred to the successor company. We will notify you of any such transfer and ensure that the recipient abides by this Privacy Policy with respect to your information.
Aggregated Data: We may share aggregated and anonymised data that does not personally identify you with third parties for various purposes. This may include sharing statistical information, usage patterns, or demographic data for research, analytics, marketing, industry insights, or other lawful purposes.
Sharing with Other Claims Agencies: We may, at our sole discretion, share your personal data with other claims agencies specialising in travel disruption claims. This sharing may occur for reasons such as exploring additional recovery options or facilitating claims resolution.
If we transfer your Personal Data to any persons under this section, we will take necessary measures to ensure that your privacy will remain secured.
PROCESSING CLAIMS FOR OTHER PASSENGERS
You must obtain explicit consent from each passenger before submitting a claim on their behalf. This consent should clearly state that you are authorised to act on their behalf in processing the claim with us. We recommend obtaining written consent for your records. You are responsible for ensuring that each passenger you represent has the opportunity to review our Privacy Policy. This will inform them about how their personal data will be collected, used, and shared in the context of the claim process.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Our website uses cookies, which are small files stored on your computer’s hard drive that may collect Personal Data. You may choose to refuse cookies, but this may affect the functionality of the website. For more information about cookies and how to manage them, please refer to our Cookies Policy.
LIMITED AUTOMATED DECISION-MAKING AND NO PROFILING
This section details our approach to automated decision-making and profiling, complying with Article 22(1) of the GDPR. We do not rely solely on automated systems for final decisions that significantly impact you. Our teams review all automated assessments to ensure accuracy and fairness. We may utilise technology from JetJustice and trusted partners to automate certain claim processing tasks such as initial eligibility checks or routing claims to the appropriate department. This allows us to provide faster and more efficient service.
We understand the importance of responsible automation. Our teams regularly evaluate both existing and future automated processes to ensure they do not have any negative or unjustified impact on you. JetJustice will not use your personal data for automated profiling for marketing purposes or any other purpose that could significantly affect you without your explicit consent. If we propose using profiling in the future, we will clearly explain the purpose and obtain your specific authorisation beforehand.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax accounting or other legal requirements). No purpose in this Privacy Policy will require us to keep your Personal Data for longer than twelve (12) months past the termination of the user’s account or the conclusion of the Services.
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise such information or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
We regularly review our data retention practices to ensure that we only retain Personal Data for as long as necessary. If you have any questions about our data retention practices or wish to request the deletion of your Personal Data, please contact us using the contact details provided in the “Contact us” section of this Privacy Policy. Please note that certain legal or regulatory requirements may require us to retain your Personal Data for a longer period of time. In such cases, we will ensure that your Personal Data is protected in accordance with this Privacy Policy and applicable laws.
DATA SECURITY
We use industry-standard encryption technologies to protect your Personal Data both in transit and at rest. Your information is stored on a secure CRM application and servers that are protected by firewalls and intrusion detection systems. We implement strict access controls to ensure that only authorised personnel can access your information and occasionally conduct security testing and vulnerability assessments to identify and address potential security risks. We also have comprehensive security policies and procedures in place to govern the collection, use, disclosure, and retention of your information. To further enhance overall account security, users are strongly advised to use strong and unique passwords to protect their accounts. These additional security measures provide an extra layer of protection to mitigate the risk of unauthorised access.
Despite our safeguards and efforts to secure your information, users are advised to note that no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Data, transmission of Personal Data to and from our website is at your own risk. You should only access the services within a secure environment.
In the event of a data breach or security incident, we will assess the scope and nature of the incident and notify the affected individuals and authorities as required by applicable laws and regulations. Your cooperation is vital in maintaining the security of your Personal Data. You are responsible for keeping your account credentials, including passwords, secure and confidential. Please refrain from sharing your account information with others and promptly notify us if you suspect any unauthorised access or use of your account.
WHAT ARE YOUR PRIVACY RIGHTS?
You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Personal Data, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Data; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your Personal Data. You can make such a request by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. If you believe we are unlawfully processing your Personal Data, you also have the right to complain to your local data protection authority.
If we rely on your consent to process your Personal Data, you have the right to withdraw this consent at any time. You may withdraw your consent at any time by contacting us or updating your preferences. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
You may unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us directly. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information: If you would at any time like to review or change the information in your account, you may log in to your account settings and update your user account. For account termination requests after completion of the claims process, you would need to email us via [email protected]. Upon receiving your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.
Cookies and similar technologies: Some Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or concerns about your privacy rights, you may email us at [email protected].
KEEPING YOU INFORMED (WITH YOUR CONSENT)
We want to keep you informed about us and how we can help you navigate through our services. However, we respect your privacy and will only send you marketing messages with your consent. By checking the appropriate box during signup or by visiting your account settings, you can choose to receive emails and/or SMS messages about our Services, features, helpful tips, occasional offers, and promotions that may be relevant to the services. If you haven’t previously opted-in or have chosen to opt-out, we will not send you marketing messages. We may, however, send you important service-related messages such as claim status updates or confirmation emails.
You can easily opt-out of receiving marketing messages at any time by following the unsubscribe instructions included in any marketing email or SMS message, updating your communication preferences through your account settings, or by reaching out to our support team. We strive to update your preferences as quickly as possible. However, due to system updates, it may take a few days for all platforms to reflect your opt-out request. During this brief period, you may still receive some marketing messages. Please note that opting out of marketing messages will not affect service-related notifications. You will continue to receive important updates regarding your claims and other essential service information.
CONTROLS FOR DO-NOT-TRACK FEATURES
Some web browsers, mobile operating systems, and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
YOUR RIGHT TO LODGE A COMPLAINT
If you have any questions or concerns about how we process your Personal Data, you can contact our Data Protection Officer (DPO) at [email protected]. Our DPO will address your concerns in a timely manner following our internal procedures. In the unlikely event you believe our processing of your data violates applicable Data Protection Laws, you have the right to lodge a complaint with a relevant supervisory authority. For residents of the EEA, you can find a list of supervisory authorities on the website of the European Commission here.
CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are processing your information.
CHANGES TO OWNERSHIP OR CONTROL
In the event of a change in ownership or control of JetJustice, such as through a merger or acquisition, your Personal Data may be transferred to the new owners. We will notify you of any such change and provide choices regarding your Personal Data.
CONTACT US
If you have questions or comments about this Privacy Policy, you may contact us our DPO via email at [email protected]. Alternatively, you may contact us by post to the following address:
JetJustice Limited
Analysis House,
117-119 Sea Road,
Sunderland,
England,
SR6 9EQ.