Effective Date: June 2024

This Privacy Policy (the “Policy”) is a legally binding agreement between Fly Raven Jet LLC, a Texas limited liability company, including its parents, subsidiaries, affiliates, successors and assigns (collectively, “Fly Raven Jet,” “Raven Jet,” “we,” “us,” or “our”), and any individual or entity that accesses, uses, or interacts with the Services (each a “User” or “you”). By accessing or using the Services, you consent to the terms of this Policy and agree that it is legally binding.

Definitions. For purposes of this Policy: “personal information” or “personal data” means any information relating to an identified or identifiable natural person; “processing” means any operation performed on personal data (including collection, storage, use, disclosure, transfer, erasure); “Controller” means the natural or legal person that, alone or jointly with others, determines the purposes and means of processing personal data.

PLEASE READ CAREFULLY. If you do not agree to this Policy, you must immediately stop accessing or using the Services.

Contact & Data Subject Requests. For questions, requests, or to exercise your rights under this Policy, contact: management@flyravenjet.com. A Data Subject Access Request (“DSAR”) may be submitted using the Fly Raven Jet Data Subject Access Request Form available at www.flyravenjet.com/dsar or by contacting management@flyravenjet.com.

Scope and Applicability

1.1. This Policy governs Fly Raven Jet’s collection, processing, storage, disclosure, and other use of personal information obtained through the Fly Raven Jet websites, mobile applications, telephone communications, in-person interactions, and any other channels by which Fly Raven Jet provides services (collectively, the “Services”).

1.2. This Policy applies to all Users, visitors, customers, members, guests, and any other natural persons whose personal information Fly Raven Jet processes in connection with the Services.

1.3. This Policy supplements — and does not replace — any specific privacy provisions in a separate written agreement you may have with Fly Raven Jet. In the event of a conflict between this Policy and a specific contractual agreement regarding personal information, the specific contractual agreement shall govern as to that conflict, except as otherwise required by applicable law.

Controller; Representatives

2.1. The Controller of personal data collected pursuant to this Policy is Fly Raven Jet LLC.

2.2. For EEA and UK residents, Fly Raven Jet may appoint a representative where required by applicable law. Requests for the identity and contact details of any representative should be sent to management@flyravenjet.com.

Information We Collect

Without limiting the generality of the foregoing, Fly Raven Jet may collect the following categories of information:

3.1. Information provided directly by you: full name, date of birth, government-issued identification numbers (e.g., passport, driver’s license), nationality, contact details (email, telephone, postal address), emergency contact details, billing and payment information, employer and business contact information, frequent flyer or loyalty program identifiers, traveler preferences (e.g., dietary, seating), special needs, and any other information you voluntarily submit.

3.2. Booking and travel information: itinerary, origin and destination, flight details, seat assignments, details of other passengers on the same booking, baggage information, and other information relevant to booking and travel facilitation.

3.3. Communications: records of communications with Fly Raven Jet, including emails, call recordings, chat transcripts, and service requests.

3.4. Information from third parties: information received from operators, channel partners, suppliers, employers, other members, travel arrangers, or public and private sources (including lists of authorized users provided by your employer).

3.5. Payment information: credit card number, expiration date, billing address, and other payment-related data provided to purchase Services. (Where possible, payment card data is processed by third-party payment processors, and Fly Raven Jet does not store full card numbers.)

3.6. User content: photographs, reviews, feedback, or other content you post to our Services or permit us to post on your behalf.

3.7. Automatically collected information: IP address, device identifiers, browser type and settings, operating system, date/time stamps, pages visited, clickstreams, referral sources, analytics data, cookies and similar tracking technologies, and geolocation information (where permitted by your device and/or browser).

3.8. Special categories of data: where necessary and only with your explicit consent or as permitted by law (e.g., medical information required for safe carriage), we may collect special category data. You must not provide special category data unless expressly requested.

How We Collect Information

4.1. Directly from you when you register, book, communicate with Member Services, complete surveys, submit content, or otherwise provide information.

4.2. From third parties such as operators, channel partners, suppliers, employers, and other members.

4.3. Automatically when you access or use the Services through cookies, log files, analytics tools, and similar technologies.

Purposes of Processing

Fly Raven Jet shall process personal information for the following lawful purposes:

5.1. To perform and fulfill contracts with Users, including the reservation, ticketing, and provision of flights and ancillary travel services.

5.2. To verify identity, perform background and watch-list checks, and satisfy security, customs, and border control obligations.

5.3. To communicate with Users about bookings, flight status, changes, operational matters, customer service, and support.

5.4. To administer membership, billing, payments, and account management functions.

5.5. To detect, prevent, and investigate fraud, security incidents, and other unlawful activity.

5.6. To comply with legal and regulatory obligations and lawful governmental requests.

5.7. To provide, personalize, and improve the Services, and to perform research, testin,g and analytics.

5.8. For marketing and promotional communications, subject to applicable consent and opt-out mechanisms.

5.9. For any other purpose to which you expressly consent.

Legal Bases for Processing (EEA / UK Users)

Where Fly Raven Jet acts as Controller and the GDPR/UK GDPR applies, Fly Raven Jet relies on the following legal bases:

6.1. Legitimate interests. Processing is necessary for Fly Raven Jet’s legitimate interests, including: (i) responding to inquiries and requests that do not require a contract; (ii) marketing and advertising (subject to your right to object); (iii) anonymization and use of de-identified data for analytics and product improvement; (iv) administration and security of the Services; (v) research and development and analytics; (vi) detection and prevention of fraud and abuse; (vii) protecting Fly Raven Jet’s legal rights and property; and (viii) facilitating corporate transactions.

6.2. Performance of a contract. Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract (e.g., booking and providing flights).

6.3. Legal obligation. Processing is necessary to comply with a legal obligation to which Fly Raven Jet is subject (e.g., disclosure to authorities, customs, tax, or other regulators).

6.4. Consent. Where required, we will rely on your consent for specified processing activities (e.g., certain types of marketing, or processing of special category data). You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

6.5. Vital interests. In limited circumstances, processing may be necessary to protect the vital interests of you or another person (e.g., medical emergency).

Disclosure and Recipients

Fly Raven Jet may disclose personal information to the following categories of recipients as necessary and permitted by law:

7.1. Affiliates, subsidiaries, and corporate group entities for purposes consistent with this Policy.

7.2. Service providers and subprocessors (payment processors, IT and hosting providers, analytics providers, customer support vendors, marketing agencies, travel arrangers, catering and ground transportation providers, and other suppliers) who perform services on Fly Raven Jet’s behalf under written contract and confidentiality obligations.

7.3. Aircraft Operators and other carriers or operators providing or arranging air transportation for you.

7.4. Fixed Base Operators (FBOs), ground transportation, and catering providers to the extent necessary to fulfil travel arrangements.

7.5. Government, law enforcement, and regulatory authorities, when required by law or to respond to lawful requests, to protect Fly Raven Jet’s rights, or to ensure safety and security.

7.6. Prospective or actual acquirers, successors, or other third parties in connection with a business transaction (merger, sale, restructure, financing, or acquisition of assets).

7.7. Other Users where you post content publicly on the Services (e.g., reviews, photos).

7.8. Aggregated or de-identified information that does not identify you may be shared broadly.

Fly Raven Jet shall use reasonable contractual and technical safeguards when transferring personal information to third parties. You expressly consent to such disclosures and releases, to the fullest extent permitted by law. Fly Raven Jet does not sell personal information to unaffiliated third parties for their own direct-marketing purposes.

International Transfers

8.1. Personal information collected by Fly Raven Jet may be processed, stored, and transferred to the United States, Switzerland, and other jurisdictions in which Fly Raven Jet or its service providers operate. Those jurisdictions may not have the same data protection laws as your home jurisdiction.

8.2. Where required by applicable law, Fly Raven Jet will implement appropriate safeguards (such as Standard Contractual Clauses, binding corporate rules, or other lawful transfer mechanisms) to protect transfers of personal information outside your jurisdiction. Requests for information about transfer safeguards may be directed to management@flyravenjet.com.

Retention

Fly Raven Jet will retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, to comply with legal, accounting ,or reporting requirements, to resolve disputes, and to enforce agreements. In exceptional cases, we may retain data for longer where necessary to establish, exercise, or defend legal claims. Specific retention periods depend on the category of data and applicable law; contact management@flyravenjet.com for details.

Cookies and Tracking Technologies

10.1. Fly Raven Jet and our service providers use cookies, clear GIFs (pixels), embedded scripts, local storage, and similar technologies to collect technical and analytics information about Users’ interactions with the Services. These technologies are used for security, analytics, performance, personalization, and advertising purposes.

10.2. You may configure your browser to refuse cookies or to notify you when cookies are set; however, some parts of the Services may not function correctly if cookies are disabled.

10.3. We use analytics services (for example, Microsoft Azure Application Insights and similar services) to measure usage and improve the Services.

Ad Networks and Targeted Advertising

Third-party ad networks and content providers may serve ads and use tracking technologies on our Services. Opt-out mechanisms may be available through industry resources such as the Digital Advertising Alliance (DAA) consumer choice page or your device/browser settings. Opting out of interest-based advertising does not prevent all ads from being shown.

Do Not Track

Our Services do not currently respond to browser “Do Not Track” signals. You may control tracking through cookie settings and device/browser privacy settings.

EEA / UK Data Subject Rights

Subject to applicable exemptions and verification, where Fly Raven Jet acts as Controller and GDPR/UK GDPR apply, you have the following rights:

13.1. Right of access. You may request confirmation as to whether we process your personal data and request a copy of such personal data.

13.2. Right to rectification. You may request correction of inaccurate or incomplete data.

13.3. Right to erasure. You may request deletion of personal data, subject to legal and contractual exceptions.

13.4. Right to restriction of processing. You may request restriction of processing in certain circumstances.

13.5. Right to data portability. Where processing is based on consent or performance of a contract and is carried out by automated means, you may request to receive your personal data in a structured, commonly used, machine-readable format.

13.6. Right to object. You may object to processing based on legitimate interests, including profiling, and to processing for direct marketing purposes.

13.7. Right to withdraw consent. Where processing is based on consent, you may withdraw your consent at any time (without prejudice to processing lawfully carried out before withdrawal).

13.8. Right to complain. If you believe Fly Raven Jet has failed to comply with applicable data protection laws, you have the right to complain with a competent supervisory authority in the Member State of your habitual residence, place of work, or place of the alleged infringement. We request that you first contact Fly Raven Jet at management@flyravenjet.com to attempt to resolve the matter; however, you retain the right to contact the supervisory authority at any time.

13.9. Requests to exercise any of the above rights should be submitted to management@flyravenjet.com. We may require information to verify your identity and may refuse manifestly unreasonable or excessive requests in accordance with applicable law.

Accessing, Correcting, and Deleting Your Information (All Users)

14.1. Account holders may access and update certain account information via their account profile. You may also contact management@flyravenjet.com to request access, correction, deletion, or restriction of your personal information.

14.2. We may require reasonable proof of identity to respond to requests and may impose reasonable fees where permitted by law (e.g., for repetitive, unfounded, or excessive requests).

Data Security

Fly Raven Jet implements reasonable technical, organizational, and administrative safeguards designed to protect personal information from accidental loss, unauthorized access, use, alteration, and disclosure. Such measures include access controls, encryption where feasible, network security, and employee training. Notwithstanding these safeguards, no transmission over the internet or storage system is 100% secure; Fly Raven Jet cannot guarantee absolute security. In the event of a security incident involving personal data, Fly Raven Jet will comply with applicable breach notification laws and notify affected individuals and regulators as required.

Children

The Services are not directed to children under sixteen (16) years of age. Fly Raven Jet does not knowingly collect personal information from children under 16. If you believe we have collected such information, contact management@flyravenjet.com, and we will take steps to delete such information as required by law.

Third-Party Sites and Links

The Services may contain links to third-party websites or services that are not controlled by Fly Raven Jet. This Policy does not apply to third-party sites. Fly Raven Jet is not responsible for the privacy practices or content of third-party websites.

Aggregate and De-Identified Data

Fly Raven Jet may use and disclose aggregate or de-identified information for any purpose.

Changes to this Policy

Fly Raven Jet reserves the right to modify this Policy in its sole discretion. Material changes will be posted on the Fly Raven Jet website and, where appropriate, notified to Users (for example, by email). Continued use of the Services after posting of a revised Policy constitutes acceptance of the revised Policy.

Limitation of Liability; Disclaimer; Indemnification

20.1. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, FLY RAVEN JET, ITS AFFILIATES, AND THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS AND SUPPLIERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES, INCLUDING LOSS OF PROFITS, LOSS OF BUSINESS, LOSS OF DATA, OR INTERRUPTION OF BUSINESS, ARISING OUT OF OR RELATED TO THIS POLICY OR THE PROCESSING OF PERSONAL INFORMATION, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

20.2. YOU AGREE TO INDEMNIFY, DEFEND AND HOLD HARMLESS FLY RAVEN JET AND ITS AFFILIATES, AND THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS, FROM AND AGAINST ANY AND ALL CLAIMS, LOSSES, LIABILITIES, DAMAGES, COSTS AND EXPENSES (INCLUDING REASONABLE ATTORNEYS’ FEES) ARISING FROM YOUR VIOLATION OF THIS POLICY, YOUR USE OF THE SERVICES, OR YOUR BREACH OF ANY REPRESENTATION, WARRANTY OR AGREEMENT MADE BY YOU HEREUNDER.

20.3. Nothing in this Section 20 shall exclude or limit liability that cannot be excluded or limited under applicable law.

Governing Law; Jurisdiction; Dispute Resolution

21.1. This Policy and any disputes arising hereunder shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of law principles.

21.2. Except as otherwise required by applicable law, the exclusive venue and jurisdiction for any dispute arising out of or related to this Policy shall be the state or federal courts located in New Castle County, Delaware, and you irrevocably consent to the personal jurisdiction of such courts.

Severability; Entire Agreement

22.1. If any provision of this Policy is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

22.2. This Policy constitutes the entire agreement between Fly Raven Jet and you with respect to its subject matter and supersedes all prior or contemporaneous communications and proposals, whether electronic, oral, or written, between you and Fly Raven Jet with respect to such subject matter.

How to Contact Us

If you have questions, complaints, or wish to exercise your rights, contact:

management@flyravenjet.com
Fly Raven Jet LLC — Attn: Data Protection Officer (or other authorized contact)
Website: www.flyravenjet.com
DSAR Form: www.flyravenjet.com/dsar

(If you require a postal address for notices or Data Protection Representative contact details, please email management@flyravenjet.com and we will provide the relevant details.)

Acknowledgment

By accessing or using the Services, you acknowledge that you have read this Policy, that you understand the terms herein, and that you consent to Fly Raven Jet’s collection, use, disclosure, and processing of your personal information as described in this Policy, subject to any rights afforded by applicable law.