1. Introduction

JetManager Aviation ("JetManager", "we", "our", or "us") is committed to protecting the privacy of visitors to our website and of the individuals who contact us through it. This Privacy Policy describes how we collect, use, store, and protect personal data, in accordance with applicable law, including Brazilian Law No. 13,709/2018 (Lei Geral de Proteção de Dados – LGPD).

By accessing or using this website, you acknowledge that you have read and understood this Privacy Policy.

2. Data We Collect

When you contact us through our website, we may collect the following personal data:

•        Full name

•        Email address

•        Phone number (if provided)

•        Content of your message or inquiry

•        Technical data collected automatically (see Section 5 – Cookies and Tracking Technologies)

3. Purpose and Legal Basis for Processing

We process personal data only for specified, explicit, and legitimate purposes. The table below summarizes our processing activities and their respective legal basis under the LGPD:

• Responding to inquiries and service requests  →  Legitimate interest / execution of pre-contractual steps

• Providing information about our services  →  Legitimate interest

• Maintaining professional communication  →  Legitimate interest / consent

• Improving website experience and performance  →  Legitimate interest

• Complying with legal obligations  →  Legal obligation

We do not use your personal data for automated decision-making or profiling.

4. Data Sharing and Third-Party Services

We do not sell, rent, or trade your personal data. We may share your information with trusted third-party service providers who assist us in operating our website and delivering our services, including:

•        Website hosting and infrastructure providers

•        Analytics platforms (e.g., Google Analytics or similar tools)

•        Email communication and CRM platforms

•        Map and location services

These providers access only the data necessary to perform their services and are required to handle it in accordance with applicable privacy laws and their own privacy policies. Some of these providers may be located outside of Brazil. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place as required by the LGPD.

5. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your browsing experience and collect analytical data. Cookies are small text files stored on your device.

We may use the following types of cookies:

•        Essential cookies: necessary for the website to function properly. These cannot be disabled.

•        Analytics cookies: help us understand how visitors interact with our website (e.g., pages visited, time spent). These cookies are only placed with your consent.

•        Preference cookies: remember your settings and choices to improve your experience.

Upon your first visit, you will be presented with a cookie consent banner. You may accept all cookies, reject non-essential cookies, or manage your preferences at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. Inquiries and contact records are typically retained for up to 5 (five) years for documentation and compliance purposes, after which they are securely deleted or anonymized.

7. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure. These measures include access controls, encrypted communications (HTTPS), and periodic security reviews.

While we take reasonable precautions, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of data transmitted via the internet.

8. Minors

Our website is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data through our website, please contact us so we may promptly delete it.

9. Your Rights as a Data Subject

Under the LGPD and, where applicable, other data protection laws, you have the right to:

•        Confirm whether we process your personal data

•        Access the personal data we hold about you

•        Correct inaccurate or incomplete information

•        Request the anonymization, blocking, or deletion of unnecessary or excessive data

•        Request the portability of your data to another service provider

•        Withdraw your consent at any time, where processing is based on consent

•        Lodge a complaint with the Brazilian data protection authority (ANPD)

To exercise any of these rights, please contact us using the information provided in Section 10. We will respond to verified requests within a reasonable timeframe and in accordance with applicable law.

10. Contact – Data Protection

For questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us at:

JetManager Aviation

Email: contact@jetmanageraviation.aero