Effective date: June 20 2023
- DATA CONTROLLER
TOPJET Executive Inc. 100 S.E. Second street, Suite 3400 – Miami (FL) 33131, duly represented by the Legal Representative. You can reach the Data Controller at the following contacts: T +1 561 867 5381 – email: [email protected].
- CATEGORIES OF PERSONAL DATA PROCESSED
An identifiable natural person is one who “can directly or indirectly be identified, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier or to one or more specific factors to the physical, physiological, genetic, mental, economic, cultural or social identity” (article 4 par. 1.1 GDPR).
The personal data that we collect for the purposes mentioned here below are specifically:
- browsing data;
- data provided voluntarily by the user when fulfilling the form of the present website: name; surname; address; city; email; phone number; personal information contained in the CV or your photo eventually submitted (Job application only).
Please note that the abovementioned list refers to personal information that we have collected directly from you within the last 12 months (according to CCPA).
- HOW WE USE YOUR PERSONAL INFORMATION: PURPOSES OF PROCESSING, LEGAL BASIS FOR THE PROCESSING AND DATA RETENTION PERIOD
PURPOSE OF PROCESSING
DATA RETENTION PERIOD
A) Navigation on this website
Controller’s legitimate interest (art. 6, par. 1 letter f GDPR): ensuring the correct browsing and usage of the website.
For the duration of the browsing session
B) Fulfillment of quotes requests via the dedicated form on the present website – eventual subsequent booking of the flight
Adoption of precontractual measures upon data subject’s request (art. 6, par. 1 letter b GDPR).
2 years from the receipt of the request. If the quotation will be confirmed and the flight will be booked, personal data will be retained for 10 years from the booking.
C) Filling out the form “Work with us“ link
Adoption of pre-contractual measures upon data subject’s request (art. 6, par. 1 letter b GDPR)
2 years from the submission of the CV.
D) Direct marketing activities: sending of advertising/promotional material, direct sales of new products and services and/or questionnaires for satisfaction surveys by automated means e-mail, telefax, SMS or other means.
We will not share any personal data with third parties for their marketing purposes.
You will be subject to the aforesaid direct marketing activities only with your prior consent.
User’s consent (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR; Federal “Telephone Consumer Protection Act” – TCPA).
Cookies are small text files that sites visited by users send to their terminals, where they are stored to be retransmitted to the same sites on subsequent visits. Cookies are used for different purposes, have different characteristics, and can be used either by the owner of the site you are visiting or by third parties. This website uses neither first-party nor third-party cookies.
- SHARING PERSONAL INFORMATIONS – CATEGORIES OF RECIPIENTS
No sharing of personal information for third parties’ marketing purposes will be performed. In particular, we disclose personal information to the following categories of recipients:
– parties that provide services for the management/maintenance of the APP;
– external parties providing hosting service of the APP;
– firms or companies within the scope of assistance and consulting relationships in the area of marketing;
– authorities responsible for fulfilling legal obligations and/or provisions of public bodies, upon request (including airport authorities).
In the preceding 12 months we have not sold any personal information.
- INTERNATIONAL TRANSFERS OF PERSONAL DATA
Our website is hosted in the US. Personal data could be also transferred to the EU countries and in particular to TOPJET Executive Italia S.r.l. for supporting the Controller in managing your booking. For more details on such transfers, please contact TOPJET at [email protected].
- PROVISION OF PERSONAL DATA
Except for what specified for browsing data – which are necessary in order to allow navigation of the website – and for personal data voluntarily provided in order to ask for a quotation or submit your job application, users are free to provide their personal data.
- YOUR RIGHTS REGARDING PERSONAL DATA
- GENERAL INFORMATION
TOPJET is committed to protecting your rights. In order to exercise them, as described here below, please contact us at
You have the right, at any time, to obtain from TOPJET the access to your personal data (article 15 GDPR), request their rectification (article 16 GDPR), their erasure (article 17 GDPR) or restriction of their processing (article 18 GDPR). Furthermore, you have the right to object anytime to your personal data processing (article 21 GDPR). Finally, you have the right to data portability, if applicable (article 20 GDPR). Furthermore, you have the right to lodge a complaint with the relevant Supervisory Authority. You are also entitled to exercise some of the abovementioned rights (e.g. right of access and to be informed, deletion, rectification, data portability, opt-out) in accordance with the existing relevant US national law/provisions (mainly: according to your US country of residence).
- INFORMATION FOR CALIFORNIA RESIDENTS UNDER “California Consumer Privacy Act Notice” – CCPA
You have the right to request that we disclose to you (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the personal information we collected about you; (iii) the business or commercial purpose for collecting personal information about you; and (iv) the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months. You also have the right to request that we delete personal information we collected from you subject to certain exceptions. You also have the right not to be discriminated in pricing and services because you exercise any of your rights under the CCPA.
- HOW TO WITHDRAW THE CONSENT PREVIOUSLY GIVEN
To stop receiving direct marketing you can write an e-mail at any time to the address [email protected] with the subject “unsubscribe from direct marketing” or use our automatic unsubscribe systems (only for email) and you will no longer be disturbed.
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ISTRUZIONI E DICITURE
Il link deve essere ben visibile (sia per dimensione che colore es. link bianco su sfondo nero) e dunque consentire una percettibile discontinuità rispetto ai contenuti del sito web**.
*Indicazioni fornite dal Business Code and Professions Code californiano (BPC)
** Come da Recommendations del California Dept. of Justice “Making your privacy practices public”.
2) DICITURA DA INSERIRE IN CALCE AL FORM PER RICHIESTA PREVENTIVI
Having read and understood the present , being aware that my consent is free and revocable at any time according to the instructions provided by the latter, I give my consent for the processing of my personal data by TOPJET Executive Inc.:
3) DICITURA DA INSERIRE IN CALCE AL FORM LAVORA CON NOI