Effective date: June 20 2023

This privacy policy describes how TOPJET Executive Inc. (hereinafter “TOPJET” or “we” or “our”) collects, uses, shares, and protects personal information. It also tells you about the rights and choices you have with respect to your personal information, and how you can reach us to get answers to your questions. This privacy policy is provided according to General Data Protection Regulation – in particular art. 13 GDPR – (hereinafter “GDPR”), as well as the relevant US privacy provisions (e.g. Federal “Telephone Consumer Protection Act” – TCPA; “California Consumer Privacy Act Notice” – CCPA; “Colorado Privacy Act” – CPA; “Connecticut Act concerning personal data privacy and online monitoring” – CTDPA; “Utah Consumer Privacy Act” – UCPA; “Virgina Consumer Data Protection Act” – CDPA) and the best practices (e.g. recommendations for businesses and policy makers “Protecting Consumer Privacy in an era of rapid change” released in 2012 by the Federal Trade Commission).

1. 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].

2. CATEGORIES OF PERSONAL DATA PROCESSED

This privacy policy covers the “personal information” that TOPJET obtains about you by browsing the present website and submitting request for quotation, job application or for booking a flight. When we use the term “personal information” we are referring to information that identifies, relates to, describes or can be associated with you.

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).

3. HOW WE USE YOUR PERSONAL INFORMATION: PURPOSES OF PROCESSING, LEGAL BASIS FOR THE PROCESSING AND DATA RETENTION PERIOD

4. COOKIES

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.

5. SHARING PERSONAL INFORMATIONS – CATEGORIES OF RECIPIENTS

We share your personal information as specified in par. 2 of this Privacy Policy with employees and/or staff acting under the Data Controller’s authority (duly instructed for the former purposes), as well as third parties contractually linked to TOPJET, in order to fulfill contractual obligations and achieve one or more of the aforesaid purposes of processing.

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).

The complete list of the recipients is regularly updated and available upon request at the contact details indicated paragraph 1. of this Privacy Policy.

In the preceding 12 months we have not sold any personal information.

6. 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].

7. 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.

Namely, provision of personal data for direct marketing activities is optional and totally free. Hence: i) your eventual denial of consent will not affect the fulfillment of the other purposes of processing detailed in par. 2 of this Privacy Policy; ii) your consent withdrawal will not affect the lawfulness of the processing based on the consent previously given.

8. 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.

9.CHANGES TO THIS PRIVACY POLICY

We may revise this privacy policy from time to time. We will notify you of changes by posting the effective date of the latest version at the top of this privacy policy.

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ISTRUZIONI E DICITURE

1) INSERIRE NEL FOOTER DI OGNI PAGINA DEL SITO UN COLLEGAMENTO IPERTESTUALE (CAPITAL LETTERS*, DENOMINATO “PRIVACY POLICY”) ALL’INFORMATIVA

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.:

for direct marketing purposes of TOPJET Executive Inc. (purpose D of this Privacy Policy)

3) DICITURA DA INSERIRE IN CALCE AL FORM LAVORA CON NOI

I agree with the processing of my personal information by TOPJET Executive Inc. for managing my job application (purpose C of this Privacy Policy)