Privacy Policy

Effective Date: May 1, 2025
Last Updated: June 20, 2025

I. Introduction and Scope of This Policy

Who We Are

This Privacy Policy is issued by TLC Jet, LLC (“TLC Jet,” “we,” “us,” or “our”). Our registered physical address is 3000 NW 59th St, Fort Lauderdale, FL 33309-6641. This disclosure is in accordance with federal law, including the CAN-SPAM Act.

For privacy-related questions, concerns, or to exercise your data protection rights, contact us via email at legal@tlcjet.com. Providing clear contact information is a key part of our commitment to transparency and is required by data protection laws, including Florida’s Information Protection Act (FIPA) and the GDPR.

Applicability of This Policy

This Privacy Policy applies to all individuals (“users,” “you,” or “your”) who access or use our website, including subdomains and other linked services (collectively, our “Services”). It governs how we collect, use, maintain, protect, and disclose personal data.

While our operations are U.S.-based, our Services are available worldwide. For users in the EEA, UK, and Switzerland, we adhere to GDPR standards, ensuring a high level of data protection for everyone interacting with our Services.

Our Commitment to Your Privacy

TLC Jet is committed to protecting your personal data and privacy rights. This policy is written in plain, clear language to help you understand how your data is handled and the rights you possess regarding it.

II. The Personal Data We Collect and How We Use It

Data You Provide Directly

When you interact with our Services (filling out forms, requesting quotes, subscribing, or contacting us), we may collect: 

• Contact Information: First and last name, email address, phone number.
• Inquiry Details: Travel routes, dates, number of passengers, and service requests. 
• Communications: Content of messages, feedback, or inquiries sent via email or web forms.

We use this data primarily to respond to your requests, provide accurate quotes, communicate about our services, and fulfill potential or existing contractual obligations.

Data We Collect Automatically

When you navigate our website, we may use server logs and cookies to gather technical and usage information, such as:

• Log Files and Device Information: IP address, browser type and version, ISP, operating system, device identifiers, and similar technical data.
• Usage Details: Pages visited, date and time, duration on pages, referring and exit pages, and clickstream data.

This data helps analyze website performance, maintain security, and optimize functionality.

Lawful Basis for Processing

We process personal data only when we have a valid legal reason:

• Consent: For sending marketing communications via email or SMS, based on explicit opt-in.
• Contractual Necessity: To perform a contract you are part of or take steps at your request prior to a contract, such as providing quotes or arranging flights.
• Legitimate Interests: To operate and improve our website, secure IT systems, prevent fraud, maintain records, and conduct limited marketing to existing customers.

Providing contact information for a quote does not automatically give consent for marketing. Separate explicit consent is requested for promotional communications.

Examples of Processing Activities and Bases

• Contact Information (name, email, phone): used to respond to inquiries and deliver quotes (Contractual Necessity); to send marketing communications (Consent).
• Travel Inquiry Details (routes, dates, passengers): used to provide accurate service quotes and arrange flights (Contractual Necessity).
• Communications Content: used to provide customer service and maintain records (Legitimate Interest).
• Technical & Usage Data (IP, browser, usage patterns): used to operate a secure and efficient website (Legitimate Interest).
• Marketing & Analytics Data (from cookies): used to personalize content and measure campaigns (Consent).

III. Cookies and Tracking Technologies

What Are Cookies?

Cookies are small text files stored on your device to remember your visit and preferences:

• Session Cookies: Temporary; deleted when the browser closes.
• Persistent Cookies: Stored for a set period or until manually deleted.
• First-Party Cookies: Set by our website; used for core functionality and analytics.
• Third-Party Cookies: Set by external domains; used for advertising, tracking, and analytics.

How We Use Cookies

• Strictly Necessary Cookies: Essential for website operation; do not require consent.
• Functional Cookies: Remember user preferences, e.g., language or region.
• Performance and Analytics Cookies: Aggregate anonymous data to improve Services.
• Marketing and Targeting Cookies: Track browsing activity and deliver personalized ads.

Your Consent and Choices

Non-essential cookies are placed only after explicit consent.

• Banner Options: Accept All, Reject All, Customize. Non-essential cookies are disabled by default until you opt-in. –
• Withdraw Consent: You can change preferences or withdraw consent anytime via a persistent “Cookie Settings” link.

IV. Marketing Communications: Email and SMS

Marketing Philosophy

We provide information about private jet charter services, offers, empty leg flights, and news of interest. Contact is only made with prior consent.

Consent for Marketing Communications

Consent is obtained through clear opt-in checkboxes on our website. Email and SMS consent are separate. Disclosures include: – Agreement to receive automated marketing messages. – SMS messages may use automated dialing systems (TCPA & FTSA). – Consent is not a condition of purchase. – Message frequency and applicable data rates. – Links to Privacy Policy and Terms of Service.

Opt-Out Procedures

• Email: Click “Unsubscribe” in any marketing email or email legal@tlcjet.com.
• SMS: Reply “STOP” (or keywords like UNSUBSCRIBE, CANCEL, QUIT) or email legal@tlcjet.com.

Special Notice for Florida Residents (FTSA)

Florida law requires a 15-day “cure period” after replying “STOP” before filing a lawsuit for unwanted messages.

V. How and Why We Share Your Personal Data

Third-Party Service Providers

We engage trusted third parties (CRM, cloud hosting, email/SMS, analytics) bound by contractual obligations and data protection agreements.

Legal Obligations and Safety

Disclosure may occur to comply with laws, protect rights, prevent wrongdoing, or enforce agreements.

Business Transfers

In mergers or acquisitions, personal data may be transferred with continued protections.

Third-Party Links

Our Services may link to external sites. We are not responsible for their content or privacy practices.

VI. Your Data Protection Rights

Your Comprehensive Rights

• Right to Be Informed
• Right of Access
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Data Portability
• Right to Object
• Right to Opt-Out of Sales/Profiling
• Rights Related to Automated Decision-Making

Exercising Rights

Email legal@tlcjet.com with a verifiable request. Identity verification may be required.

Response Timeline

We respond within 45 days (with possible 15-day extension if needed).

Right to Appeal

Instructions provided if a request is denied.

Non-Discrimination

Exercising rights will not affect service, pricing, or quality.

VII. International Data Transfers

Safeguards

• Standard Contractual Clauses (SCCs) for EU/UK transfers.
• Transfer Impact Assessments (TIAs) to evaluate risks and ensure protection.

VIII. Data Security and Retention

Data Security Measures

• Encryption (TLS and at rest)
• Access Controls (role-based)
• Regular Assessments
• Incident Response Plan
• Employee Training

Data Retention Policy

• Lead & Marketing Data: 2 years
• Customer & Contract Records: 7 years
• Opt-Out Lists: indefinite
• Website Analytics Data: 2 years
• Legal Holds: as required

Data is securely deleted or anonymized after retention period.

IX. Children’s Privacy

Age Limitations

Services not intended for children under 18; comply with COPPA and FDBR.

Information for Parents

Email legal@tlcjet.com to request deletion of children’s data.

X. “Do Not Track” Signals

We do not alter practices in response to DNT signals. Control is provided via cookie consent manager and marketing opt-out options.

XI. Data Breach Notification Procedures

Commitment

We have an Incident Response Plan to investigate, mitigate, and notify parties of breaches.

Notification Requirements

• FIPA (Florida): Individuals within 30 days; state dept if 500+; consumer agencies if 1,000+.
• GDPR: Notify supervisory authority within 72 hours for EEA/UK residents.

Content of Notification

Include breach nature, data affected, mitigation steps, and contact info.

Third-Party Breaches

Vendors must notify within 10 days.

XII. Governing Law and Dispute Resolution

Governing Law

State of Florida, USA.

Dispute Resolution

• Contact legal@tlcjet.com first.
• Unresolved disputes: arbitration in Broward County, Florida via JAMS.
• Class Action Waiver: individual arbitration only.
• Confidentiality maintained.

XIII. Accessibility Statement

Commitment

Website and content accessibility per WCAG 2.2 Level AA.

Feedback and Assistance

Email legal@tlcjet.com with “Accessibility” in the subject line for assistance.

XIV. Changes to Our Privacy Policy

Updates posted on our website with revised “Last Updated” date. Continued use constitutes acceptance.