Privacy Policy

1. Introduction

Jet Genius Holdings ("Jet Genius Holdings," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our services, including our website, mobile applications, telephone inquiries, and charter booking and flight services.

Jet Genius Holdings operates as a private jet charter broker. We do not operate aircraft directly. All flights are arranged through properly licensed air carriers operating under FAA Part 135 or Part 121 certificates, or their foreign regulatory equivalents, as required by 14 C.F.R. Part 295. This distinction is relevant to your privacy because certain information you provide must be shared with the operating carrier and applicable government authorities as a condition of arranging your travel.

Please read this Privacy Policy carefully. By accessing our website, submitting an inquiry, booking a charter flight, or otherwise engaging our services, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein. If you do not agree, please discontinue use of our services.

We reserve the right to amend this Privacy Policy at any time. Material changes will be posted on our website with an updated effective date. Continued use of our services following any such amendment constitutes your acceptance of the revised Policy.

2. Information We Collect

We collect information from you directly, automatically, and from third parties. The categories of information we may collect include:

2.1 Information You Provide Directly

• Identity and contact information: full name, company name, mailing address, email address, telephone number.
• Travel information: departure and arrival airports, preferred travel dates and times, number and identity of passengers, special requests (dietary, accessibility, pets, ground transportation), and passport or government-issued identification information for all passengers as required by applicable law or operating carriers.
• Payment information: credit card, bank wire, or other financial account details necessary to process your charter booking. Payment card data is processed through PCI-DSS compliant third-party payment processors; we do not store full card numbers on our systems.
• Communications: records of correspondence, including emails, telephone calls, and text messages between you and our team. Telephone calls may be recorded or monitored for quality assurance and training purposes.
• Preferences and profile information: flight history, cabin preferences, catering preferences, and any other details you choose to share to enhance your experience.

2.2 Sensitive Personal Information

In connection with certain service requests, we may collect categories of information treated as sensitive under applicable law, including:

• Health and medical information (e.g., allergies, mobility needs, oxygen requirements, or fitness-to-fly documentation) if you request or require special assistance.
• Passport numbers, nationality, and visa status, as required for international travel and government reporting.

We request and use sensitive information only when reasonably necessary to arrange requested services, accommodate passenger needs, prevent fraud, or comply with legal obligations. We do not use sensitive personal information for marketing or for any purpose not directly related to your service request.

2.3 Information Collected Automatically

When you visit our website or use our digital platforms, we may automatically collect:

• Device and browser information: IP address, browser type and version, operating system, device identifiers.
• Usage data: pages visited, time and date of your visit, referring URLs, clickstream data, and time spent on pages.
• Approximate geolocation derived from your IP address.
• Cookies and similar tracking technologies. See Section 9 (Cookies and Digital Advertising Technologies) for a full description.

2.4 Information from Third Parties

We may receive information about you from:

• Travel agents, brokers, or concierge services that book flights on your behalf.
• Operating air carriers with whom we place your charter.
• Credit reporting agencies, fraud prevention services, and sanctions screening providers used in connection with payment verification or regulatory compliance.
• Advertising and analytics platforms, which may associate a cookie identifier or device identifier with information about your interactions with our website and our digital advertising.

3. How We Use Your Information

We use personal information for the following purposes:

• Service fulfillment: to arrange, confirm, and manage your charter flight booking, communicate itinerary details, coordinate with operating carriers, and address service-related requests or changes.
• Passenger manifest and regulatory compliance: to prepare required passenger manifests and to transmit passenger information to operating air carriers, the Transportation Security Administration (TSA), U.S. Customs and Border Protection (CBP), and equivalent foreign border and customs authorities, as required by law.
• Sanctions screening: to verify that you and your passengers are not subject to any applicable economic sanctions, trade restrictions, or travel bans imposed by the U.S. Treasury Department (OFAC), the U.S. State Department, or other relevant governmental authorities.
• Payment processing: to authorize and process payments for charter services.
• Account and relationship management: to maintain records of your bookings, preferences, and service history.
• Safety and security: to protect the safety of passengers, crew, and aircraft, and to investigate potential fraud or misuse of our services.
• Legal compliance: to comply with applicable federal, state, and local laws, FAA regulations, Department of Transportation (DOT) requirements, and any other binding legal or regulatory obligations.
• Communications: to respond to your inquiries, send booking confirmations, and provide flight-related updates. For Jet Genius Holdings employee and authorized internal staff SMS programs, message content is limited to internal operational and workflow notifications as described in the applicable Employee SMS Notifications Terms of Service.
• Marketing and promotions (with your consent where required): to send you information about Jet Genius Holdings services, promotions, or relevant aviation updates. You may opt out at any time. See Section 10.
• Digital advertising: to deliver relevant advertisements on our website and on third-party platforms, and to measure the effectiveness of those campaigns. See Section 9.
• Service improvement: to analyze usage patterns and client feedback to improve our website, booking process, and overall service quality.
• Dispute resolution and legal proceedings: to assert or defend claims arising from our services.

4. Legal Basis for Processing

Where applicable law requires us to identify a legal basis for processing your personal information, we rely on the following:

• Contract performance: processing necessary to fulfill your charter booking and related service obligations.
• Legal obligation: processing required to comply with applicable laws, regulations, and government directives, including aviation security and customs regulations.
• Legitimate interests: processing for fraud prevention, sanctions screening, network security, and service improvement, where such interests are not overridden by your rights.
• Consent: processing for marketing communications where we have obtained your affirmative consent, such as email sign-up.
• Legitimate interests (tracking and analytics): processing for website analytics and advertising effectiveness, based on your implied consent through continued use of our website as described in Section 9.

5. How We Share Your Information

We do not sell your personal information. We may share your information with the following categories of recipients:

5.1 Operating Air Carriers

To arrange your charter, we must share relevant passenger and itinerary information with the licensed air carrier that will operate your flight. That carrier may have its own privacy practices, and you should review their applicable policies.

5.2 Government and Regulatory Authorities

We are legally required to share passenger manifest data and related information with government agencies including, but not limited to, the TSA, CBP, FAA, and equivalent foreign authorities. We may also disclose information in response to lawful subpoenas, court orders, or government investigations.

5.3 Service Providers

We engage third-party vendors who provide services on our behalf, including payment processing, IT infrastructure and hosting, CRM and booking platforms, fraud detection and sanctions screening, email communication services, and digital advertising and analytics platforms. These vendors are contractually bound to use your information only as directed by us and to maintain appropriate security measures.

5.4 Advertising and Analytics Partners

As described in Section 9, we work with advertising and analytics partners who may receive information about your interactions with our website and our digital ads. These partners operate under their own privacy policies and may combine data from our site with data from other sources for advertising purposes. You can find information on opting out of interest-based advertising in Section 9.

5.5 Travel Agents and Brokers

If your booking was arranged through a travel agent, concierge, or broker, we may communicate relevant booking details with that intermediary as necessary to coordinate your travel.

5.6 Business Transfers

In connection with a merger, acquisition, financing, reorganization, or sale of all or substantially all of our business assets, your information may be transferred to the successor entity, subject to confidentiality protections and applicable law.

5.7 Legal and Safety Disclosures

We may disclose your information when we believe in good faith that disclosure is necessary to: (a) comply with applicable law or legal process; (b) protect the rights, property, or safety of Jet Genius Holdings, our clients, or the public; or (c) detect, prevent, or address fraud, security, or technical issues.

5.8 With Your Consent

We may share your information with third parties for purposes not described in this Policy with your explicit prior consent.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected. Our retention periods are based on the nature of the information, the purpose for which it was collected, and applicable legal, tax, and accounting requirements — not on any single regulatory mandate. Key retention benchmarks include:

• Charter booking and transaction records: retained for a minimum of five (5) to seven (7) years from the date of the flight or transaction, reflecting applicable statutes of limitations for contract claims, IRS guidance on business records, and our general accounting obligations. The operating air carrier that performs each flight bears its own separate recordkeeping obligations under applicable FAA regulations.
• Passenger manifest information: retained for the period required by applicable law and the reasonable needs of our business, generally commensurate with the booking record to which the manifest relates.
• Payment records: retained for a minimum of five (5) years to comply with financial reporting and audit requirements.
• Marketing preference and consent records: retained until you opt out or withdraw consent, and for an additional period sufficient to demonstrate compliance with applicable law.
• General inquiry and correspondence records: retained for three (3) years from the date of last contact, unless a longer period is required by law or active dispute.
• SMS messaging consent records: Users may opt in through the consent flow applicable to the specific messaging program they request, and consent records are retained to demonstrate compliance with applicable messaging requirements.

You may request earlier deletion subject to the limitations described in Section 11.

7. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted transmission via TLS/SSL, access controls and authentication requirements, vendor security assessments, and employee training on data handling obligations.

No method of electronic transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you as required by applicable law.

8. International Data Transfers

Jet Genius Holdings is based in the United States. Your personal information may be transferred to, stored, and processed in the United States or in other countries as necessary to provide our services, comply with applicable law, or work with the vendors and carriers that support your travel. Data protection standards in those countries may differ from those of your country of residence.

For international charter flights, passenger data will be shared with relevant foreign border and customs authorities as required by the laws of the departure and destination countries. Where applicable law requires it, we implement appropriate safeguards for cross-border transfers, such as standard contractual clauses or other recognized transfer mechanisms.

9. Cookies and Digital Advertising Technologies

Our website and digital properties use cookies and a range of other tracking and advertising technologies. This section describes the full scope of those tools, the purposes they serve, and how you can control them.

9.1 Types of Technologies We Use

• Cookies: small text files placed on your device by our web server. Session cookies expire when you close your browser. Persistent cookies remain on your device until they expire or you delete them.
• Pixel tags and web beacons: transparent images (often 1x1 pixel) embedded in web pages or emails that signal when content has been loaded or an action has been taken. We use these to measure campaign effectiveness and email open rates.
• JavaScript tags and SDKs: code embedded in our pages that collects behavioral data and enables advertising and analytics functions.
• Third-party embedded content: some pages may embed content or widgets served by third parties (e.g., maps, social sharing buttons, video players), which may independently collect information about your visit pursuant to those third parties' own privacy policies.

9.2 Categories of Cookies and Their Purposes

• Strictly necessary cookies: required for core website functionality (navigation, security, session management). Cannot be disabled without breaking the site.
• Functional cookies: remember your preferences and settings (e.g., language, region) to improve your experience on return visits.
• Analytics cookies: collect aggregated, pseudonymous data about how visitors use our site (e.g., pages visited, time on page, exit pages). We currently use Google Analytics for this purpose. This data helps us improve website performance and content. Google Analytics operates under Google's own privacy policy, available at policies.google.com/privacy.
• Advertising and targeting cookies: placed by us or our advertising partners to build a profile of your interests based on your browsing behavior and to serve you relevant advertisements — including on our site and on third-party sites and platforms (remarketing or retargeting). These cookies may track you across websites over time.
• Social media cookies: placed by social media platforms when you interact with embedded features (e.g., a "Share" button). These platforms may use the data for their own targeting purposes, independent of our control.

9.3 Advertising Partners and Remarketing

We use and anticipate using advertising platforms — including Google Ads, Meta (Facebook and Instagram), LinkedIn, and other programmatic ad networks — to deliver interest-based advertising and to measure campaign effectiveness. Depending on the platform, these partners may:

• Place cookies or pixel tags on our site to recognize your device when you visit other websites or apps, and serve you advertisements related to our services (remarketing or retargeting).
• Combine data about your activity on our site with data they hold about you from other sources to build or enrich an advertising profile.
• Measure conversions — such as form submissions or booking inquiries — and attribute them to specific advertising campaigns.
• Apply their own tracking technologies independently of the cookies we place. Each partner operates under its own privacy policy: Google, Meta, LinkedIn. We encourage you to review those policies to understand how each platform handles your data.

To opt out of interest-based advertising by participating ad networks broadly, visit the Network Advertising Initiative opt-out page or the Digital Advertising Alliance opt-out page. Opting out does not stop you from seeing ads; it means ads you see will be less personalized.

9.4 Consent and Your Controls

By continuing to use our website after reviewing this Privacy Policy, you consent to our use of cookies and similar technologies as described in this Section. You are not required to accept non-essential cookies to access our website, and you may limit or disable them using the controls below.

• Browser controls: you may configure your browser to block or delete cookies at any time. Most browsers allow you to refuse all cookies, accept only certain types, or delete existing cookies. Blocking some cookies may impair website functionality. Consult your browser's help documentation for instructions specific to your browser.
• Opt-out of interest-based advertising: opt-out links for participating ad networks are provided in Section 9.3 above. To opt out of Google Analytics specifically, you may install the Google Analytics Opt-out Browser Add-on. To opt out of Google's advertising cookies, visit Google Ads Settings.
• Direct opt-out request: if you would like to request that we suppress advertising tracking associated with your device or email address, contact us at privacy@jetgeniusholdings.com with the subject line "Advertising Opt-Out." We will work with our advertising partners to honor your request to the extent technically feasible.
• Do Not Track: we do not currently alter our data practices in response to browser Do Not Track signals, as no uniform technical standard for honoring those signals exists across the industry.

10. Third-Party Links

Our website may contain links to third-party websites, services, or content that are not owned or controlled by Jet Genius Holdings. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy notices of any third-party sites you visit. The inclusion of a link on our website does not imply our endorsement of that site or its privacy practices.

11. Marketing Communications

With your consent where required by law, we may send you marketing emails or SMS messages about Jet Genius Holdings services, promotions, empty leg opportunities, or relevant aviation updates. You may opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email;
• Replying "STOP" to any marketing text message; or
• Contacting us directly at privacy@jetgeniusholdings.com.

Opting out of marketing communications will not affect transactional communications related to an existing or pending booking.

12. SMS Messaging Privacy

If you opt in to receive SMS messages from Jet Genius Holdings, we may use your mobile number and related consent records to provide the particular messaging program you requested, including employee operational and workflow notifications, client flight requests and trip updates, or, where separately authorized by your consent, marketing and other SMS programs. Message frequency varies depending on the program and your interactions or settings. Message and data rates may apply. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

13. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Access: request a copy of the personal information we hold about you.
• Correction: request that inaccurate or incomplete information be corrected.
• Deletion: request that we delete your personal information, subject to our legal retention obligations.
• Restriction: request that we restrict the processing of your information in certain circumstances.
• Portability: request that we provide your personal information in a structured, machine-readable format.
• Objection: object to processing where we rely on legitimate interests as the legal basis.
• Withdraw Consent: where processing is based on consent, withdraw your consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us as described in Section 15. We will respond to verifiable requests within the timeframes required by applicable law. Residents of certain states may have additional rights under applicable state privacy legislation. We will evaluate and honor such requests to the extent required by law.

14. Children's Privacy

Our services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from children under 13 without verifiable parental consent. If a minor is a passenger on a charter arranged through our services, we collect only the information necessary to fulfill the flight booking and comply with applicable regulations. If you believe we have inadvertently collected personal information from a child under 13 without appropriate consent, please contact us immediately and we will take steps to delete such information.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Jet Genius Holdings

Email: privacy@jetgeniusholdings.com

Website: www.jetgeniusholdings.com

We will acknowledge receipt of your request and respond within the timeframe required by applicable law, generally within 30 to 45 days, subject to any legally permitted extensions.

16. Applicable Law

This Privacy Policy is governed by applicable U.S. federal and state law as relevant to the particular interaction, together with any other privacy laws that may apply to our operations. This Policy does not constitute a forum selection clause or a waiver of any rights you have under applicable consumer protection law.

Dispute resolution terms — including governing law, choice of forum, and arbitration provisions — are set forth in our Terms of Use and Charter Agreement, which are separate documents. To the extent any inconsistency exists between this Policy and those documents with respect to the handling of personal information, this Privacy Policy governs.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. When we make material changes, we will post the revised Policy on our website with an updated effective date and, where appropriate, provide additional notice (such as a notice on our homepage or via email to registered clients). Your continued use of our services after the effective date of any revised Policy constitutes your acceptance of the changes.