Privacy Policy

This Privacy Notice for JETUP LTD (doing business as JetUp) (“we,” “us,” or “our”) describes how and why we access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• visit our website at https://jetup.com or any website of ours that links to this Privacy Notice;
• download and use our mobile application (JetUp), or any other application of ours that links to this Privacy Notice; or
• engage with us in other related ways, including sales, marketing, or events.

Reading this Privacy Notice will help you understand your privacy rights and choices. We decide how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. Questions may be sent to support@jetup.com.

Summary of key points

This summary highlights key points. Use the table of contents below to find the full section.

• What personal information do we process? We may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. See What information do we collect?
• Do we process sensitive personal information? We do not process sensitive personal information.
• Do we collect information from third parties? We may collect limited information from public databases, marketing partners, social media platforms, and other outside sources. See Information collected from other sources.
• How do we process your information? We process it to provide, improve, and administer the Services, communicate with you, for security and fraud prevention, and to comply with law, and only when we have a valid legal reason. See How do we process your information?
• When and with whom do we share personal information? We may share information in specific situations and with specific categories of third parties. See When and with whom we share.
• How do we keep your information safe? We use organizational and technical measures, but no electronic transmission or storage can be guaranteed 100% secure. See How we keep your information safe.
• What are your rights? Depending on where you live, you may have rights regarding your personal information. See Your privacy rights.
• How do you exercise your rights? Contact us or submit a request via our DSAR page. We will consider and act on requests in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information you voluntarily provide when you register on the Services, express interest in our products or Services, participate in activities on the Services, or otherwise contact us. The personal information we collect depends on your interactions, your choices, and the features you use, and may include:

• names
• phone numbers
• email addresses
• contact preferences

Sensitive information. We do not process sensitive information.

Social media login data. We may let you register using an existing social media account such as Facebook, X, or another provider. If you do, we collect certain profile information from that provider, as described in How do we handle your social logins?

If you use our application(s) and grant access or permission, we may also collect:

• Geolocation information. We may request permission to track location-based information from your mobile device, continuously or while you use the App, to provide location-based services. You can change this in your device settings.
• Mobile device access. We may request access to certain device features, including calendar, reminders, storage, and other features. You can change this in your device settings.
• Mobile device data. We automatically collect device information such as device ID, model, manufacturer, operating system, version and configuration, application identifiers, browser type and version, hardware model, ISP or mobile carrier, and IP address (or proxy). We may also collect information about the phone network, platform, unique device ID, and which App features you accessed.
• Push notifications. We may send push notifications about your account or certain features. You can turn these off in your device settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for internal analytics and reporting. All personal information you provide must be true, complete, and accurate, and you must notify us of changes.

Information automatically collected

In short: Some information — such as your IP address and browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (such as your name) but may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, and information about how and when you use our Services. This is primarily needed to maintain security and operation, and for internal analytics. Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and usage data. Diagnostic, usage, and performance information our servers collect, which may include IP address, device information, browser type and settings, activity in the Services (dates, pages viewed, searches, features used), and device event information such as system activity, crash dumps, and hardware settings.
• Device data. Information about the computer, phone, tablet, or other device you use, which may include IP address (or proxy), device and application identifiers, location, browser type, hardware model, ISP or mobile carrier, operating system, and configuration.
• Location data. Precise or imprecise location depending on your device and settings. We may use GPS and other technologies, including location based on IP address. You can refuse access or disable Location settings, though some features may then be unavailable.

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To provide relevant marketing, offers, and services, and to update our records, we may obtain information about you from public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and other third parties. This may include mailing addresses, job titles, email addresses, phone numbers, intent or behavior data, IP addresses, social media profiles and URLs, and custom profiles, for targeted advertising and event promotion.

If you interact with us on a social media platform using your social media account (for example Facebook or X), we may receive personal information such as your name, email address, and gender. You may have the right to withdraw consent. See Your privacy rights. What we collect from your social media account depends on that account’s privacy settings. Those platforms’ own use of your information is not governed by this Privacy Notice.

2. How do we process your information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process personal information for reasons that may include:

• to facilitate account creation and authentication and otherwise manage user accounts;
• to deliver and facilitate delivery of services you request;
• to respond to inquiries and offer support;
• to send administrative information, including changes to our terms and policies;
• to fulfill and manage orders, payments, returns, and exchanges;
• to request feedback and contact you about your use of our Services;
• to send marketing and promotional communications, in line with your preferences (you can opt out at any time; see Your privacy rights);
• to deliver targeted advertising tailored to your interests and location;
• to protect our Services, including fraud monitoring and prevention;
• to identify usage trends so we can improve the Services;
• to determine the effectiveness of marketing and promotional campaigns; and
• to save or protect an individual’s vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your personal information?

In short: We process personal information only when we have a valid legal reason under applicable law — for example consent, contract, legal obligation, or legitimate interests.

If you are located in the EU or UK

GDPR and UK GDPR require us to explain the legal bases we rely on. We may rely on:

• Consent. You have given permission to use your personal information for a specific purpose. You can withdraw consent at any time.
• Performance of a contract. Processing is necessary to fulfill our contractual obligations to you, including providing the Services, or at your request before entering into a contract.
• Legitimate interests. Processing is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights. For example, we may process personal information to send information about offers, display relevant advertising, analyze and improve the Services, support marketing, diagnose problems, prevent fraud, and improve user experience.
• Legal obligations. Processing is necessary to comply with law, cooperate with a regulator or law enforcement, exercise or defend legal rights, or disclose information as evidence in litigation.
• Vital interests. Processing is necessary to protect your vital interests or those of a third party, such as threats to someone’s safety.

In legal terms, we are generally the “data controller” under European data protection laws for the personal information described in this Privacy Notice, because we determine the means and purposes of the processing. This Privacy Notice does not apply to personal information we process as a “data processor” on behalf of customers under a data processing agreement. In those cases the customer is the controller. For those practices, read the customer’s privacy policy.

If you are located in Canada

We may process your information if you have given express consent for a specific purpose, or where consent can be inferred (implied consent). You can withdraw consent at any time. In some exceptional cases, Canadian law may permit processing without consent, including where collection is clearly in an individual’s interests and consent cannot be obtained in time; for investigations and fraud prevention; for certain business transactions; where contained in a witness statement needed to assess an insurance claim; to identify injured, ill, or deceased persons and communicate with next of kin; where we have reasonable grounds to believe someone is a victim of financial abuse; where seeking consent would compromise an investigation of a breach of an agreement or of Canadian or provincial law; where disclosure is required by subpoena, warrant, or court order; where information was produced in the course of employment, business, or profession consistent with those purposes; for journalistic, artistic, or literary purposes; or where the information is publicly available as specified by regulation. We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.

4. When and with whom do we share your personal information?

In short: We may share information in the situations described below and with the following categories of third parties.

We may share data with vendors, consultants, and other third-party service providers who perform services for us and need access to that information to do so. We have contracts designed to help safeguard your personal information: they may not use it except as we instruct, they may not share it with anyone other than us, and they commit to protect it and retain it only for the period we instruct.

Categories of third parties we may share personal information with include:

• Ad networks
• AI platforms
• Data storage service providers
• Payment processors
• Performance monitoring tools
• Retargeting platforms
• Sales and marketing tools
• Social networks
• Testing tools
• Website hosting service providers
• Order fulfillment service providers
• Data analytics services
• Affiliate marketing programs
• Product engineering and design tools
• User account registration and authentication services

We may also share personal information in these situations:

• Business transfers. In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business.
• Google Maps Platform APIs. We may share information with Google Maps Platform APIs (for example Maps API or Places API) when you make location-specific requests. This may include location, search, interaction, and route data. Google Maps uses GPS, Wi-Fi, and cell towers to estimate location. We may cache your location on your device for one (1) month. You may revoke consent by contacting us. Google Maps Platform APIs store and access cookies and other information on your devices. Users in the EEA or UK should also review our Cookie Policy.

5. Do we use cookies and other tracking technologies?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar technologies (such as web beacons and pixels) when you interact with our Services. Some tracking technologies help us maintain security, prevent crashes, fix bugs, save preferences, and support basic site functions. We also permit third parties and service providers to use tracking technologies for analytics and advertising, including managing advertisements, tailoring ads to your interests, or sending abandoned-cart reminders depending on your preferences. Those parties may show advertising on our Services or on other websites.

To the extent these technologies are a “sale” or “sharing” (including targeted advertising) under applicable US state laws, you can opt out as described in United States residents. Specific information about cookies and how to refuse them is in our Cookie Policy. You can also open Cookie Settings.

Google Analytics

We may share information with Google Analytics to track and analyze use of the Services. Advertising features we may use include Google Analytics Demographics and Interests Reporting and Remarketing with Google Analytics. To opt out of being tracked by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt-out tools include optout.networkadvertising.org and networkadvertising.org/mobile-choice. For Google’s practices, see Google Privacy & Terms.

6. Do we offer artificial intelligence-based products?

In short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services we offer AI-powered products, features, or tools (“AI Products”). This Privacy Notice governs your use of those AI Products. We provide AI Products through third-party providers (“AI Service Providers”), including OpenAI, Anthropic, and Google Cloud AI. Your input, output, and personal information will be shared with and processed by those providers to enable the AI Products for the purposes described in legal bases. You must not use the AI Products in a way that violates any AI Service Provider’s terms or policies.

Our AI Products are designed for functions including:

• AI search
• natural language processing
• AI bots

All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with those third parties.

7. How do we handle your social logins?

In short: If you register or log in with a social media account, we may have access to certain information about you.

Our Services may let you register and log in using third-party social media account details (for example Facebook or X). If you do, we receive certain profile information from that provider. That information varies by provider but often includes your name, email address, friends list, and profile picture, and other information you choose to make public. We use it only for the purposes described in this Privacy Notice or otherwise made clear on the Services. We do not control, and are not responsible for, other uses of your information by the social media provider. Review their privacy notice and set your preferences on their sites and apps.

8. How long do we keep your information?

In short: We keep your information as long as necessary to fulfill the purposes in this Privacy Notice, unless a longer period is required by law.

We keep personal information only as long as needed for the purposes in this notice, unless a longer retention period is required or permitted by law (for example tax, accounting, or other legal requirements). No purpose in this notice requires us to keep personal information longer than three (3) months after termination of the user’s account. When we no longer have a legitimate business need to process personal information, we will delete or anonymize it, or, if that is not possible (for example because it is in backup archives), securely store it and isolate it from further processing until deletion is possible.

9. How do we keep your information safe?

In short: We aim to protect personal information through organizational and technical security measures.

We have implemented appropriate technical and organizational measures designed to protect personal information we process. No electronic transmission over the internet or storage technology can be guaranteed 100% secure, so we cannot promise that unauthorized third parties will never defeat our security or improperly collect, access, steal, or modify your information. Transmission of personal information to and from the Services is at your own risk. Access the Services only in a secure environment.

10. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18, or the equivalent age specified by law in your jurisdiction.

We do not knowingly collect, solicit, or market to children under 18 (or the equivalent age in your jurisdiction), nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 (or the equivalent age) or that you are the parent or guardian of such a minor and consent to that minor’s use of the Services. If we learn that we have collected personal information from a user under 18 (or the equivalent age), we will deactivate the account and take reasonable steps to delete the data. If you become aware of any such data, contact us at support@jetup.com.

11. What are your privacy rights?

In short: Depending on your location, you may have rights that allow greater access to and control over your personal information. You may review, change, or terminate your account depending on your country, province, or state of residence.

In some regions (including the EEA, UK, Switzerland, and Canada) you have rights under data protection law. These may include the right to: (i) request access to and a copy of your personal information; (ii) request rectification or erasure; (iii) restrict processing; (iv) data portability, if applicable; and (v) not be subject to automated decision-making. If a decision with legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a way to request human review. In certain circumstances you may also object to processing. Make a request using the contact details in How can you contact us. We will consider and act on requests in accordance with applicable law.

If you are in the EEA or UK and believe we are unlawfully processing your personal information, you may complain to your Member State data protection authority or the UK data protection authority. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing consent. If we rely on consent (express or implied, as applicable), you may withdraw it at any time by contacting us or updating your preferences. Withdrawal does not affect the lawfulness of processing before withdrawal, or processing on other lawful grounds.

Opting out of marketing. You can unsubscribe from marketing communications by replying STOP or UNSUBSCRIBE to SMS we send, or by contacting us. We may still send service-related messages needed to administer your account, respond to requests, or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Sharing with subcontractors who support services such as customer service is permitted. Text messaging originator opt-in data and consent will not be shared with third parties.

Account information

To review or change account information or terminate your account, contact us using the details below. Upon a request to terminate, we will deactivate or delete your account and information from our active databases. We may retain some information to prevent fraud, troubleshoot, assist investigations, enforce our legal terms, or comply with law.

Most browsers accept cookies by default. You can usually set your browser to remove or reject cookies. Doing so may affect certain features of the Services. Questions about your privacy rights may be sent to support@jetup.com.

12. Controls for Do-Not-Track features

Most browsers and some mobile operating systems and applications include a Do-Not-Track (“DNT”) setting. No uniform standard for recognizing DNT signals has been finalized, so we do not currently respond to DNT browser signals or other automatic “do not track” mechanisms. If a standard is adopted that we must follow, we will describe that practice in a revised Privacy Notice. California law requires us to say how we respond to DNT signals: because there is no industry or legal standard for honoring them, we do not respond to them at this time.

13. Do United States residents have specific privacy rights?

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and details about the personal information we maintain, how we have processed it, correction of inaccuracies, a copy, or deletion. You may also have the right to withdraw consent. These rights may be limited by applicable law.

Categories of personal information we collect

The table below shows categories of personal information we have collected in the past twelve (12) months. Examples are illustrative and do not necessarily reflect what we collect from you. For a full inventory, see What information do we collect?

We may also collect other personal information when you interact with us in person, online, by phone, or by mail, including when you:

• receive help through our customer support channels;
• participate in customer surveys or contests; and
• use the Services and we respond to your inquiries.

We use and retain collected personal information as needed to provide the Services, or for:

• Categories A, B, F, G, H, and K — as long as the user has an account with us.

Sources of personal information are described in What information do we collect? Use and sharing are described in How do we process your information?

We collect and share personal information through targeting/marketing cookies, social media cookies, and beacons, pixels, or tags.

We may disclose personal information to service providers under a written contract. We may use personal information for our own business purposes, such as internal research for technological development. That is not a “sale” of personal information. Categories of third parties to whom we disclose personal information for a business or commercial purpose are listed under When and with whom we share.

In the preceding twelve (12) months we have shared personal information with:

• AI platforms
• Retargeting platforms
• Data analytics services
• Social networks
• Affiliate marketing programs
• Ad networks

We have not sold personal information to third parties in the preceding twelve (12) months.

Your rights

Under certain US state data protection laws, and subject to legal limits, you may have the right to:

• know whether we are processing your personal data;
• access your personal data;
• correct inaccuracies;
• request deletion;
• obtain a copy of personal data you previously shared with us;
• non-discrimination for exercising your rights; and
• opt out of processing for targeted advertising (or “sharing” under California law), sale of personal data, or profiling that produces legal or similarly significant effects.

Depending on your state, you may also have rights to:

• access the categories of personal data being processed (including under Minnesota law);
• obtain a list of categories of third parties to which we have disclosed personal data (including California, Delaware, and Maryland);
• obtain a list of specific third parties to which we have disclosed personal data (including Minnesota and Oregon);
• obtain a list of third parties to which we have sold personal data (including Connecticut);
• review, understand, question, and depending on where you live, correct how personal data has been profiled (including Connecticut and Minnesota);
• limit use and disclosure of sensitive personal data (including California); and
• opt out of collection of sensitive data and personal data collected through voice or facial recognition (including Florida).

How to exercise your rights

Contact us by submitting a request on our DSAR page, by emailing support@jetup.com, by visiting jetup.com, or by using the contact details at the end of this notice. You can opt out of selling, targeted advertising, or profiling by disabling cookies in Cookie Settings.

Under certain US state laws you may designate an authorized agent. We may deny a request from an agent that does not submit proof of authorization.

Request verification

We will need to verify that you are the person about whom we have information. We will only use personal information provided in your request to verify identity or authority. If we cannot verify identity from information we already hold, we may request additional information for verification and fraud prevention. If an authorized agent submits the request, we may need additional information to verify your identity, and the agent must provide your written signed permission.

Appeals

Under certain US state laws, if we decline to take action on your request, you may appeal by emailing support@jetup.com. We will inform you in writing of any action taken or not taken, including reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” law

California Civil Code Section 1798.83 permits California residents to request, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of those third parties in the immediately preceding calendar year. Submit such a request in writing using the contact details in How can you contact us.

14. Do other regions have specific privacy rights?

In short: You may have additional rights based on the country where you reside.

Australia and New Zealand

We collect and process personal information under Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. This Privacy Notice satisfies the notice requirements of those Acts, including what we collect, from which sources, for which purposes, and other recipients. If you do not provide personal information necessary for the applicable purpose, we may be unable to offer the products or services you want, respond to requests, manage your account, or confirm your identity and protect your account. You may request access to or correction of your personal information using the contact details in How can you review, update, or delete data. If you believe we are unlawfully processing your personal information, you may complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You may request access to or correction of your personal information using the contact details in How can you review, update, or delete data. If you are unsatisfied with how we address a complaint about processing of personal information, you may contact:

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

15. Representative

We have appointed Prighter Group and its local partners as our privacy representative and point of contact for the European Union. Prighter provides a way to exercise privacy-related rights (for example requests to access or erase personal data). To contact us via Prighter or to exercise data subject rights, visit https://app.prighter.com/portal/JetUp.

16. Communications and consent

By providing contact information such as a phone number or email address, you consent to receive communications from JetUp via SMS, WhatsApp, or email, where you have opted in or such communication is otherwise permitted by law. Standard message and data rates may apply to SMS or WhatsApp messages as determined by your mobile carrier. We will not share your mobile number or other contact information with third parties for their marketing or promotional purposes. You can opt out of marketing communications at any time. For SMS or WhatsApp, reply STOP (or equivalent) to unsubscribe. For emails, use the unsubscribe link or contact us directly. Once we receive an opt-out, we will stop sending the corresponding communications.

17. Do we make updates to this notice?

In short: Yes. We will update this notice as needed to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this notice. If we make material changes, we may notify you by posting a notice or by sending a notification. We encourage you to review this Privacy Notice frequently.

18. How can you contact us about this notice?

Questions or comments about this notice may be sent to support@jetup.com or by post to:

JETUP LTD
27 Old Gloucester Street
London, United Kingdom WC1N 3AX
United Kingdom

If you are a resident in the European Economic Area, JETUP LTD is the data controller of your personal information. We have appointed Prighter Group as our representative in the EEA. You can contact them regarding our processing of your information at https://app.prighter.com/portal/JetUp or by post to:

Schellinggasse 3/10
Vienna 1010
Austria

19. How can you review, update, or delete the data we collect from you?

Depending on the laws of your country or US state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, or deletion. You may also have the right to withdraw consent. These rights may be limited by applicable law. To request to review, update, or delete your personal information, submit a request on our DSAR page or email support@jetup.com.