Introduction.
This is the privacy policy of Hanover Jets, a private aviation house registered in England and Wales. It applies to all correspondence with the office, the use of the website at hanoverjets.com, and the administration of every charter the office arranges.
The office holds information on correspondents for one reason only: to arrange the charter and the correspondence that surrounds it. It is not held for resale, for advertising, or for any third-party purpose. This document sets out what is held, how it is used, and what the correspondent can do about it.
Information the office holds.
The office holds two categories of correspondent information: that which is provided directly, and that which is collected automatically through use of the website.
Provided directly
- Name, salutation, and contact details, including email address and telephone number
- Routing details, dates, party size, and preferences expressed in correspondence
- Passport and identification details, where required for international charter and ground handling
- Payment instructions, processed through the office’s regulated payment partners and not stored by the office
- Correspondence with the office, including emails, telephone notes, and meeting records
Collected automatically
- IP address, browser type, operating system, and device identifiers
- Pages visited on hanoverjets.com, the time spent on each, and the order of visits
- The referring website, where one is recorded
- Cookie-stored preferences (see section vi)
How information is used.
The office uses correspondent information only for the purposes for which it was provided, and only in the administration of charter and the correspondence that surrounds it. Specifically:
- To arrange charter flights and reply to quote requests with three vetted options
- To administer the House Account, where the correspondent has opened one
- To send the Journal to subscribers, where the correspondent has subscribed
- To maintain the office’s records of past charter, for the purposes of future correspondence and standing arrangements
- To improve the website and the office’s processes
- To meet the office’s legal, regulatory, and tax obligations
The office does not use correspondent information for targeted advertising, does not build behavioural profiles, and does not make automated decisions of legal or similarly significant effect.
With whom it is shared.
The office shares correspondent information only as necessary to arrange the charter the correspondent has requested, and only with parties bound by appropriate confidentiality undertakings. In practice this means:
- The aircraft operator chartered for a specific routing, and only for that routing
- Ground handlers at the origin and destination airports, for the purposes of arrival and departure
- Customs and immigration authorities, where required for international routings
- The office’s payment partners, for the processing of charter invoices
- The office’s professional advisers, where required for legal, accounting, or regulatory purposes
- Regulatory authorities and law-enforcement bodies, where required by applicable law
Your rights.
Under the UK General Data Protection Regulation and equivalent laws in other jurisdictions, every correspondent has the following rights in relation to information the office holds:
- The right to be informed about what is held and how it is used, which this document is intended to satisfy
- The right of access to a copy of the information the office holds
- The right to rectification of any information that is inaccurate or incomplete
- The right to erasure of information that is no longer required, subject to the office’s retention obligations
- The right to restrict processing in certain circumstances
- The right to data portability, for information provided directly
- The right to object to certain types of processing
- The right to withdraw consent at any time, where the office relies on consent
- The right to lodge a complaint with the Information Commissioner’s Office or another supervisory authority
To exercise any of these rights, the correspondent should write to [email protected]. The office will reply within thirty days, and ordinarily within a working week.
Cookies and analytics.
The website uses cookies and similar technologies sparingly. Strictly necessary cookies are used to operate the website; functional cookies remember correspondent preferences; analytics cookies provide aggregated information on how the website is used. The office does not use advertising cookies, and does not allow third-party trackers from advertising networks.
The full Cookie Policy, including the categories used, their purposes, and their retention periods, is at /cookies.
Retention.
The office holds correspondent information for as long as is necessary to fulfil the purposes set out in section iii, and as required by applicable law. In practice:
- Quote requests not converted to charter: held for twelve months, then deleted
- Charter records: held for seven years from the date of the charter, as required by HMRC and equivalent tax authorities
- House Account records: held for the duration of the account, and for seven years after closure
- Journal subscriber records: held until the subscriber unsubscribes, then deleted within ninety days
- Website analytics: retained in aggregated form for twenty-six months
International transfers.
The office has four offices: London, Zürich, Dubai, and New York. Correspondent information may be transferred between these offices for the administration of charter. Where information is transferred outside the United Kingdom or the European Economic Area, the office relies on the appropriate safeguards in Article 46 of the UK GDPR, including Standard Contractual Clauses and adequacy decisions where these apply.
Aircraft operators and ground handlers are located in many countries. Where charter is arranged into a destination outside the UK or EEA, the necessary information is transferred to operators and handlers in that destination, on the basis that the transfer is necessary for the performance of the contract requested by the correspondent.
Security.
The office maintains appropriate technical and organisational measures to protect correspondent information against unauthorised access, alteration, disclosure, and destruction. These include encryption of information in transit and at rest, access controls limiting who within the office can view what, regular review of the office’s security practices, and contractual security requirements with every third party that processes information on the office’s behalf.
No system is entirely secure. In the unlikely event of a personal data breach affecting a correspondent, the office will notify the correspondent and the Information Commissioner’s Office within the timeframes required by law.
Children’s privacy.
The website and the office’s services are directed to adult correspondents and their advisers. The office does not knowingly collect information from any person under the age of sixteen. Where a charter is arranged for a party that includes a minor, the necessary travel information is provided by the booking adult and held only for the duration of that charter.
Changes to this policy.
This policy is reviewed annually and may be updated to reflect changes in the office’s practices or in applicable law. Material changes will be notified to correspondents in correspondence with the office, and a notice will be placed at the top of this page for thirty days. The version number and date at the head of this document are kept current.
Contact the office.
Questions about this policy, requests to exercise the rights set out in section v, or any other matter relating to correspondent information should be directed to the office, in the first instance to the Privacy Officer.
Hanover Jets Limited
14 Berkeley Square
London, W1J 6DT
United Kingdom
Email: [email protected]
Telephone: +44 (0) 20 7946 0XXX
A correspondent unsatisfied with the office’s response may lodge a complaint with the Information Commissioner’s Office at ico.org.uk, or with the equivalent supervisory authority in the correspondent’s place of residence.