MyJet

These www.My-Jet.net website Privacy Policy guidelines refer to the processing of personal data by MyJet in relation to visits to the website and the interaction of users with the services and functions offered, pursuant to Italian law.

In the preparation of this Privacy Policy, MyJet has drawn on Recommendation No 2/2001, which European personal data protection authorities in the Working Group established by article 29, Directive No 95/46/CE, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online and, in particular, the methods, timescale and nature of the information that the data controller must provide to users when same are connected to web pages, independently of the purpose of the connection, in order to ensure the transparency and lawfulness of data collection practices.

MyJet is aware of how important it is to protect the confidentiality of personal data and undertakes to take the greatest care to comply with principles designed to ensure that web navigation is safe, protected and controlled, remembering that whenever personal data are provided on the web there is the risk that such data be intercepted and used illicitly by third parties, making it impossible to guarantee total security and protection for the personal data provided.

The website may contain links to other sites to which this Privacy Policy does not apply. This Privacy Policy is periodically revised by MyJet; the version currently published on the website was revised on 4 December 2010.

MyJet invites users to check the Privacy Policy periodically to receive information regarding any changes.

INFORMATION CIRCULAR ON PERSONAL DATA PROCESSING PURSUANT TO LEGISLATIVE DECREE No 196/2003

This Privacy Policy is also the information circular to interested parties pursuant to article 13, Legislative Decree No 196/2003 (“Privacy Code”). It identifies the Data Controller responsible for supervising and managing the data collected through the Website, describes and clarifies the type of personal data collected, the personal data collection methods used when visitors navigate through the Website, the purposes of processing the personal data collected, the extent to which the personal data are disclosed to third parties, the measures which MyJet adopts to protect such data, and the methods of exercising the rights recognised by the Privacy Code.

The data controller is the company MyJet.

The data manager is Mr Fabrizio Bertacchi, legal representative of the company, to whom all requests and comments in relation to this Privacy Policy should be addressed.

TYPE OF DATA - COLLECTION AND PURPOSES OF PROCESSING

Navigation data

The collection and processing of personal data relating to Website users is generally limited to navigation data alone, i.e. the data which the information systems and software procedures used by this Website acquire during normal operations and the transmission of which is inherent in the use of Internet communication protocols. This category of data includes the IP addresses or domain names of the computers of users who visit the website [the addresses of the resources requested in URI (Uniform Resource Identifier) notation], the time of the request, the method used to send the request to the server, the size of the file obtained in response, the numerical code indicating the server response status (successful, error, etc.) and other parameters regarding the operating system running on the user’s computer. This information is not collected for the purposes of association to identified users and persons, but which due to its very nature may permit the identification of users as a result of processing and association with other data held by third parties. The navigation data is collected and processed by MyJet for the sole purposes of obtaining anonymous statistical information about access to and use of the Website, to check on correct operation and to improve content and functionality. The navigation data are deleted immediately after anonymous processing. Such data may be used to ascertain responsibility in the event of criminal action to the detriment of the Website or performed through the Website. With the exception of this possibility, users’ navigation data are generally not retained for more than seven days or as established by applicable regulations.

Data provided voluntarily by users

MyJet also collects and processes the personal data (such as, for example, identification data, personal data, email addresss, credit card/bank account details in the event of commercial transactions in order to perform the service requested, third party data only where strictly necessary for the purposes of the service requested and exclusively in the pursuit of such purpose) provided voluntarily by users and following express consent, where requested, in order to be able to offer the user the services offered by the Website, such as flight searches and bookings, the performance of services regarding flight searches and bookings, registration with the Website, registration for programmes or other initiatives offered through the Website, or in the case of requests to receive information or information, promotion and advertising material, newsletters, or for the purposes of assessing any request for employment or resume sent in by users.

Also with the freely and voluntarily provided express consent of users, MyJet collects and processes personal data (including, in addition to the data indicated above, information regarding habits and/or interests and/or preferences and/or buying attitudes, particularly with regard to air transport and more in general to the tourism sector), also for the purposes of individual and group profiling, internal statistics, loyalty programmes and for marketing purposes, such as for example sending users - also by means of newsletters, email, text and multimedia messages - information and updates to products services and promotional offers.

Further specific purposes regarding individual processing activities are identified in detail in the website sections regarding the services provided from time to time. Individual sections contain specific information on personal data processing pursuant to article 13 of the Privacy Code.

Unless specific consent is requested for the processing of personal data in relation to specific purposes (in which case users will be asked for their consent in the manner indicated), by continuing to use this Website users consent to the processing of their personal data as established in this Privacy Policy.

MyJet may also process the personal data of users, even without their consent, in the cases provided by the Privacy Code (among others: to perform obligations deriving from a contractual relationship or to comply with legal and regulatory obligations or EU rules).

OPTIONAL NATURE OF DATA CONTRIBUTION

With the exception of the above comments on navigation data and without prejudice to requirements in certain Website sections with regard to specific processing purposes, users are free to provide their personal data in order to request the services offered by MyJet, including registration, information transmission, profiling and marketing. The failure to provide personal data may, however, make it impossible to fulfil users’ requests.

The personal data requested to perform the flight search or booking contract, and to provide services relating to flight searches and bookings, are essential for the specific purpose of processing operations. The failure to contribute such data could make it impossible to perform the services provided for by the contract.

COOKIES

Cookies are small text files stored on users’ hard disks, which are sent by a server to the user’s browser when a website is visited. Cookies make it possible to create a connection between the user’s computer and website navigation functions, enabling the server to download webpages faster on subsequent visits to the site and making it possible to recognise any profile created by the user.

The Website makes use of session cookies for specific, limited purposes. The Website makes use of cookies to facilitate Website navigation for users and to provide registered users with easier access. Session cookies are strictly limited to the transmission of session ID numbers (random numbers generated by the server), in order to permit secure and effective Website exploration, and may be eliminated manually using the functions provided by the browser used. The cookies used following registration collect personal data to offer users more functional access to the registered users’ area and personalised website navigation.

The cookies used by MyJet do not permit any form of control over the user’s computer, nor can they launch programmes or download viruses; furthermore, the cookies used cannot be exploited to access the user’s computer or the information stored on it.

Browsers are set up to accept cookies automatically. Users may change their browser settings to disable this function (using the “Help” section on the tool bar which describes how to prevent the reception of cookies and other technologies used to track users or, usually, by selecting the “Tools - Internet Options - Privacy” item and choosing the preferred settings). If cookies are disabled, it will still be possible to navigate through the Website, but its use or functions may be limited.

MyJet has no form of access and/or control over the cookies used by other websites which are linked to by our Website and therefore declines all liability in this regard, while encouraging users to read the Privacy Policies provided by such third party websites.

PLACE AND METHOD OF PROCESSING

The personal data collected by our Website, which is hosted by the company Seeweb, are processed and stored by an electronic system installed at the headquarters of the data controller company and are accessed exclusively by the employees, collaborators and parties engaged by the data controller, or engaged for the purposes of occasional maintenance operations.

The server which hosts the Website is located in Italy at the company Seeweb, which is a data controller in its own right.

Other MyJet parent and/or subsidiary and/or associated companies may be involved in the collection and processing of personal data.

The personal data collected by MyJet are processed mainly by IT or automated tools, but may also be processed without the use of electronic instruments using manual tools. In any case, the data is stored only for the time needed for the specific purposes for which it was collected from time to time and in compliance with current legislation. We collect and process data in compliance with current regulations in order to protect the confidentiality, integrity, comprehensiveness and availability of personal data and to minimise the risk of cancellation, destruction, loss, alteration (even accidental), unauthorised access, prohibited or incorrect use of data and illegitimate disclosure.

The Data Controller may not be held liable in any manner for untruthful or imprecise information sent to users, or for any information regarding users provided by third parties, also fraudulently, nor may any liability be attached to the Data Controller for any consequences which derive from same.

Likewise, the Data Controller may not be held liable for any damage of any nature caused directly or indirectly by accessing and/or navigating through the Website.

PERSONAL DATA COMMUNICATION

MyJet communicates users’ personal data within the limits and in the manner established in this Privacy Policy.

The personal data provided by users are used for the sole purpose of performing the service requested and may be accessed by personnel employed by MyJet or other companies charged with processing and by the aforementioned Data Manager.

Users’ personal data may be communicated to professionals, independent collaborators, third parties who perform technical and organisation services or on which MyJet relies to perform the services requested and in general for the processing purposes specified above.

The personal data may be communicated to any party envisaged as a legitimate recipient for legal or regulatory purposes including, by way of example but without limitation, the countries and authorities of countries which require airlines to communicate passenger data - identification, travel documents, passport, visa - for security reasons: in this case the collection and processing of personal data is for this purpose.

For the same purposes, users’ personal data may be transferred to MyJet parent/subsidiary/associated companies, including companies based outside the European Union which can guarantee a different or lower level of personal data protection than that offered by the Privacy Code, or within the European Union, with the free and optional consent of the user.

The third parties to which the data may be transmitted as indicated above will act as independent data controllers.

RIGHTS OF INTERESTED PARTIES

Pursuant to article 7 of the Privacy Code, users have the right at any time to obtain confirmation of the existence or non-existence of personal data collected and processed by MyJet, to know the content, origin and the logic, methods and purposes of processing, to verify accuracy and to request that they be supplemented, updated or rectified. Users also have the right to request the deletion of their personal data, their transformation into an anonymous format or their blocking if processed in violation of the law, as well as to oppose the processing of such data for legitimate reasons and, in any case, the sending of advertising or direct sales material or materials for the purposes of market research or commercial communication.

To exercise their rights or in relation to any question or request regarding personal data processing, users may contact the Data Manager.

MyJet manages the data regarding its Customers in compliance with the provisions of the regulations introduced by Legislative Decree No 196, 30 June 2003, on the “Personal data protection code”, which ratifies the European Union Directive on this subject in Italy.