Privacy Policy

2.1 Information You Provide Directly

• Account registration data: full name, email address, password (encrypted), and role.
• Contact form submissions: name, email, phone number, company name, area of interest, preferred contact method, and message content.
• Quote request data: travel type (private jet, group travel, hotel/resort), origin, destination, departure and return dates, number of travelers, special requirements, contact name, company name, contact email, and contact phone.
• Membership and billing data: subscription tier selection, billing cycle preference, and payment method information processed securely through Stripe.
• Travel coordination data: passenger names, passport or identification details (when required for international bookings), dietary or medical preferences, seating preferences, and other logistics information necessary to fulfill travel arrangements.
• Communications: records of your correspondence with our concierge team, including emails, phone call notes, and chat messages within the client portal.

2.2 Information Collected Automatically

• Device and usage data: IP address, browser type and version, operating system, device identifiers, referring URL, pages visited, time spent on pages, and click patterns.
• Cookies and tracking technologies: session cookies, authentication cookies, analytics cookies, and preference cookies. See Section 7 below for details.
• Location data: approximate geographic location derived from your IP address. We do not collect precise GPS location data from your device.

2.3 Information from Third Parties

• Authentication data: when you register or log in using Google, we receive your name, email address, and profile picture from the authentication provider.
• Payment data: we receive confirmation of successful transactions and subscription status from Stripe, our payment processor. We do not receive or store your full credit card number.
• Travel partner data: when we coordinate trips through third-party operators, we may receive itinerary confirmations, booking references, and status updates relevant to your travel arrangements.

• Providing services: processing quote requests, coordinating travel arrangements, managing bookings, and delivering concierge membership benefits.
• Account management: creating and maintaining your client portal account, authenticating your identity, and communicating with you about your account.
• Billing and payments: processing subscription payments, managing recurring billing, issuing invoices and receipts, and handling billing inquiries through Stripe's billing portal.
• Customer support: responding to your inquiries, resolving issues, and providing travel coordination assistance.
• Marketing communications: sending you information about membership tiers, service offerings, and travel opportunities. You may opt out of marketing communications at any time (see Section 10).
• Service improvement: analyzing usage patterns, improving our website and portal functionality, and developing new service offerings.
• Security and fraud prevention: detecting, preventing, and investigating fraudulent activity, unauthorized access, or violations of our terms.
• Legal compliance: fulfilling legal obligations, responding to legal requests, and protecting our legal rights and interests.

• Consent: where you have provided affirmative consent to the processing of your personal data for a specific purpose, such as marketing communications or optional data collection.
• Contractual necessity: processing required to fulfill our obligations under a contract with you, including processing quote requests, coordinating travel, and managing your membership subscription.
• Legal obligation: processing necessary to comply with federal, state, or local laws, including tax reporting, financial recordkeeping, and breach notification requirements under the Florida Information Protection Act (FIPA).
• Legitimate business interests: processing that is reasonably necessary to operate our business, secure our systems, prevent fraud, and maintain the integrity of our services, provided that your interests and rights do not override these interests.

• Service providers: we share information with third-party vendors who provide services on our behalf, including Stripe (payment processing), Google (authentication and analytics), email delivery providers, and our itinerary and quote management platforms. These vendors are contractually bound to protect your information and use it only for the purposes we specify.
• Travel partners: when you book travel through us, we share necessary booking and passenger information with aircraft operators, hotels, ground transportation providers, and other travel suppliers to fulfill your itinerary. We share only the information required to complete each booking.
• Legal authorities: we may disclose information in response to a valid legal request, court order, or government inquiry, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business transfers: in the event of a merger, acquisition, asset sale, or other transfer of all or a portion of our business, your information may be transferred to the acquiring entity. We will notify you before your information is transferred under these circumstances.
• With your consent: we may share information with third parties when you provide explicit consent to do so.

7.1 Types of Cookies We Use

• Essential cookies: required for the website to function properly, including authentication, session management, and security. These cannot be disabled.
• Preference cookies: remember your choices such as language, display settings, and form inputs so you do not have to re-enter them.
• Analytics cookies: help us understand how visitors interact with our website by collecting and reporting information anonymously.
• Marketing cookies: used to deliver relevant content and advertising based on your interests, where you have provided consent.

7.2 Managing Cookies

• You can control and delete cookies through your browser settings. Disabling essential cookies may prevent you from using certain features of our website, such as the client portal login. For information on managing cookies in your specific browser, please refer to the browser's help documentation.

• Active accounts: personal information associated with your client portal account is retained for the duration of your membership and for three (3) years after account closure, unless you request earlier deletion (subject to legal retention requirements).
• Travel booking records: itinerary details, passenger manifests, and booking confirmations are retained for seven (7) years to comply with federal transportation regulations and for tax audit purposes.
• Quote requests: data submitted through the quote request form is retained for two (2) years from the date of submission.
• Contact form submissions: inquiries submitted through the contact form are retained for one (1) year after resolution.
• Payment and billing records: transaction records, invoices, and billing statements are retained for seven (7) years in compliance with federal tax recordkeeping requirements under 26 U.S.C. § 6501 and Florida tax regulations.
• Security logs: IP addresses, login records, and system activity logs are retained for twelve (12) months for security and fraud prevention purposes.

• Encryption: all data transmitted between your browser and our servers is encrypted using TLS (Transport Layer Security) 1.2 or higher. Passwords are stored using one-way cryptographic hashing.
• Access controls: access to personal information is restricted to authorized personnel who require it to perform their job functions. Role-based access controls are enforced across all systems.
• Secure payment processing: all payment transactions are processed through Stripe, which is certified under the Payment Card Industry Data Security Standard (PCI-DSS) at Level 1, the highest level of certification.
• Regular security assessments: we conduct periodic security reviews and vulnerability assessments of our systems and applications.
• Vendor management: we require third-party service providers to maintain appropriate security standards and enter into data processing agreements that obligate them to protect your information.

9.1 Limitation

• No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information using commercially acceptable means, we cannot guarantee absolute security. You acknowledge this risk when using any online service.

10.1 Rights Under the Florida Digital Bill of Rights (FDBR)

• Right to access: you may request a copy of the personal information we have collected about you, along with the categories of information, the sources, the purpose of collection, and the third parties with whom we have shared it.
• Right to correct: you may request that we correct inaccurate or incomplete personal information about you.
• Right to delete: you may request that we delete your personal information, subject to certain exceptions such as information needed to complete a transaction, fulfill a contractual obligation, detect fraud, or comply with legal requirements.
• Right to opt out: you may opt out of the sale of your personal information or the use of your personal information for targeted advertising. Glades Air does not sell personal information, but you may opt out of targeted advertising and marketing communications at any time.
• Right to limit: you may request that we limit the use of your sensitive personal information to purposes necessary to provide the services you requested.
• Right to appeal: if we decline to take action on your request, you may appeal our decision. We will respond to your appeal within forty-five (45) days.

10.2 Federal and Other Rights

• CAN-SPAM Act: you may opt out of receiving commercial email communications from us at any time by clicking the unsubscribe link in any marketing email or by contacting us at Travel@gladesair.com. We will process your opt-out request within ten (10) business days.
• Telephone Consumer Protection Act (TCPA) and Florida Do Not Call Act: if you provide your phone number, you consent to receive calls and text messages related to your travel arrangements and account. You may revoke this consent at any time by replying STOP to any text message or by contacting us. We do not use auto-dialers or pre-recorded messages for marketing without your express written consent.
• Children's privacy (COPPA): our services are not directed to children under the age of thirteen (13), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will promptly delete it.

10.3 Authorized Agents

• You may designate an authorized agent to submit privacy requests on your behalf. The authorized agent must provide written authorization signed by you, and we may require verification of your identity and the agent's authority before processing the request.

• Conduct a prompt investigation to determine the scope of the breach and the specific data affected.
• Notify affected individuals in writing without unreasonable delay, and no later than thirty (30) days following the determination of the breach, unless a shorter timeframe is required by law or law enforcement.
• If the breach affects five hundred (500) or more Florida residents, notify the Florida Department of Legal Affairs (Office of the Attorney General) as required by FIPA.
• Provide affected individuals with a clear description of the incident, the types of information compromised, steps individuals can take to protect themselves, and a contact method for obtaining additional information.
• Coordinate with law enforcement agencies when appropriate, and may delay notification if law enforcement determines that notification will impede a criminal investigation.

• Glades Air LLC
• Orlando, Florida
• Phone: 407-900-0622
• Email: Travel@gladesair.com
• Website: gladesair.com