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PRIVACY POLICY - SASH AVIATION LTD

1. INTRODUCTION

Sash Aviation Ltd (“Sash Aviation”, “we”, “our”, or “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website or engage our private aviation services.

We aim to align with internationally recognized data protection principles, including the General Data Protection Regulation (GDPR) and other applicable privacy laws.

2. INFORMATION WE COLLECT

We may collect and process the following categories of personal data:

a. Personal Identification Data

Full name
Email address
Phone number
Nationality

b. Travel & Booking Information

Passport details
Date of birth
Passenger manifests
Special travel requests (dietary, medical assistance)

c. Financial Information

Billing address
Payment details (processed securely via third-party providers)

d. Technical Data

IP address
Browser type and version
Device information
Website usage data (via cookies)

3. HOW WE USE YOUR DATA

We use your personal data for the following purposes:

To arrange and manage aircraft charter bookings
To communicate with you regarding your flights or inquiries
To process payments and issue invoices
To comply with aviation, customs, and immigration requirements
To improve our website, services, and customer experience
To send marketing communications (only where consent is provided)

4. LEGAL BASIS FOR PROCESSING

We process your data based on:

a. Contractual necessity, to fulfill charter agreements
b. Legal obligations, aviation and regulatory compliance
c. Legitimate interests, service improvement and fraud prevention
d. Consent - for marketing communications

5. DATA SHARING AND DISCLOSURE

To deliver our services effectively, we may share your data with:

a. Licensed aircraft operators and crew
b. Ground handlers and airport authorities
c. Immigration, customs, and security agencies
d. Payment processors and financial institutions
e. IT service providers and booking platforms
f. All third parties are required to handle your data securely and in accordance with applicable laws.

6. INTERNATIONAL DATA TRANSFERS

Due to the global nature of private aviation, your personal data may be transferred and processed in countries outside your country of residence. We take appropriate safeguards to ensure your data remains protected in accordance with international standards.

7. DATA RETENTION

We retain personal data only for as long as necessary to:

a. Fulfill contractual obligations
b. Comply with legal and regulatory requirements
c. Resolve disputes and enforce agreements
d. After this period, data is securely deleted or anonymized.

8. YOUR RIGHTS

Depending on applicable laws, you may have the following rights:

a. To access your personal data
b. To request correction of inaccurate data
c. To request deletion of your data
d. To restrict or object to processing
e. To withdraw consent (where applicable)
f. To request data portability
g. Requests can be made by contacting us using the details below.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your data, including:

a. Secure servers and encryption protocols
b. Restricted access to personal data
c. Regular security monitoring and updates

However, no system is completely secure, and we cannot guarantee absolute security.

10. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies to:

a. Improve functionality and performance
b. Analyze website traffic and user behavior
c. Enhance user experience

You can control or disable cookies through your browser settings.

11. THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those external sites.

12. CHILDREN’S PRIVACY

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors without appropriate consent.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date.

14. CONTACT INFORMATION

For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

Sash Aviation Ltd,
4B King AJ Turner Crescent,
Wuye, Abuja, Nigeria
Email: info@sashaviation.com

15. CONFIDENTIALITY (VIP CLIENT PROTECTION)

Sash Aviation Ltd recognizes that many of its clients require the highest level of discretion.

a. All client information, including but not limited to:

Identity
Travel itineraries
Aircraft movements
Passenger manifests shall be treated as strictly confidential.

b. We shall not disclose any such information to third parties except:

Where required for operational execution (e.g., operators, authorities)
Where required by law or regulatory authorities

Sash Aviation implements internal policies to ensure:

a. Restricted access to sensitive data
b. Staff confidentiality obligations
c. Secure communication protocols

No client information will be used for publicity, marketing, or reference purposes without prior written consent.

16. NON-DISCLOSURE FOR HIGH-PROFILE CLIENTS (NDA FRAMEWORK)

For high-profile individuals, corporate executives, or public figures:

Sash Aviation may enter into separate Non-Disclosure Agreements (NDAs) upon request.

In the absence of a separate NDA, the following applies:

a. All employees, contractors, and partners are deemed bound by strict confidentiality obligations
b. Any disclosure of client identity, travel details, or business engagements is strictly prohibited

This obligation extends to:

Third-party operators
Ground handlers
Crew members

Sash Aviation reserves the right to require reciprocal confidentiality from clients where sensitive operational or business information is shared.

17. DATA BREACH NOTIFICATION (GDPR-ALIGNED)

In the event of a personal data breach that may pose a risk to your rights and freedoms:

Sash Aviation will:

a. Investigate and assess the nature and scope of the breach
b. Take immediate steps to mitigate any risks

Where required under applicable data protection laws:

a. Notify the relevant supervisory authority within 72 hours of becoming aware of the breach
b. Inform affected individuals without undue delay where the breach poses a high risk

Notifications will include:

i. Nature of the breach
ii. Likely consequences
iii. Measures taken or proposed to address it

Sash Aviation maintains internal procedures for:

a. Incident detection
b. Response and escalation
c. Documentation of breaches

18. DISCRETION & ANONYMITY POLICY

Upon request, Sash Aviation may:

a. Use anonymized passenger identifiers
b. Limit data visibility to essential personnel only
c. Arrange discreet airport handling and private terminals (FBOs)