1. Identity of the Data Controller
In compliance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), the user is informed that the personal data collected through the website https://www.justflyexecutive.com will be processed by:
Controller: LEARNBROKERS SL
Trade Name: Just Fly Executive
CIF: B55230890
Contact Email: info@justflyexecutive.com
Data Protection Officer (DPO) or equivalent contact: rgpd@justflyexecutive.com
2. What Personal Data Do We Process?
We collect only data that is adequate, relevant, and limited to what is necessary for each purpose. We may process:
2.1. Data Provided by the User:
Full Name
Phone Number
Email Address
Message or information included in forms
Billing information (if applicable)
Information necessary to provide private or charter flight services
Marketing Preferences
2.2. Data Generated by Browsing:
IP Address
Device Identifiers
Website Usage Data
Technical, personalization cookies, and, if the user consents, analytical cookies (Google Analytics).
For more information, please refer to the Cookies Policy.
2.3. Data Derived from the Service:
Request History
Information necessary to manage bookings or quotes
Contact details of passengers authorized by the client (if applicable)
3. Purposes and Legal Bases for Processing
3.1. Management of Inquiries, Quote Requests, or Contact
Purpose: To respond to requests made via form, email, or phone.
Legal Basis: User Consent (art. 6.1.a GDPR) and application of pre-contractual measures (art. 6.1.b GDPR).
3.2. Provision of Private Flight Services / Brokerage
Purpose: To manage reservations, contracts, and communications with the client.
Legal Basis: Performance of the contract (art. 6.1.b GDPR).
3.3. Communications Necessary for Service Provision
Purpose: Sending notices, incidents, contractual documentation, or operational information.
Legal Basis: Performance of the contract.
3.4. Commercial Communications (Marketing)
Purpose: Sending information about services, promotions, or offers.
Legal Basis:
User Consent (art. 6.1.a GDPR).
Legitimate Interest for past clients (art. 6.1.f GDPR), in accordance with art. 21.2 LSSI (soft opt-in).
3.5. Web Analytics
Purpose: To measure user interaction and improve the website using Google Analytics.
Legal Basis: User Consent (art. 6.1.a GDPR).
Analytical cookies are installed only when the user accepts them.
3.6. Compliance with Legal Obligations
Purpose: To meet tax, accounting, or regulatory requirements.
Legal Basis: Legal Obligation (art. 6.1.c GDPR).
4. How Long Do We Retain Data?
Type of Data | Duration |
|---|---|
Contact / Form Data | 12 months |
Client Data | Throughout the contractual relationship |
Accounting or Tax Obligations | 6 years (Commercial Code) |
Commercial Communications | Until consent is withdrawn |
Cookies | As specified in the Cookies Policy |
The data will be deleted or anonymized when no longer necessary.
5. To Whom Do We Disclose Data?
We do not sell or transfer data to third parties.
We may disclose data only to:
Essential providers for service provision (air operators, handling companies, ground transport, etc.).
Technology providers (hosting, email, CRM, analytics).
Legal Obligations (Tax Authorities, courts, or public agencies if necessary).
Google LLC, when the user accepts analytical cookies.
All operate under data processing contracts as per art. 28 GDPR.
6. International Data Transfers
The use of Google Analytics may entail transfers to the USA or third countries.
Google applies:
Standard Contractual Clauses (SCC),
complementary security measures,
and processing subject to GDPR.
The user can consult details in Google's official documentation.
7. User Rights
The user may exercise the following rights:
Right to Access
Right to Rectification
Right to Erasure
Right to Restriction
Right to Object
Right to Portability
Right to Withdraw Consent
Right to Not Be Subject to Automated Decisions
To exercise them:
📧 rgpd@justflyexecutive.com
(Attach a copy of an identification document if necessary.)
The user may also file a complaint with the supervisory authority:
Spanish Data Protection Agency (AEPD) — www.aepd.es
8. Data Security
LEARNBROKERS SL applies appropriate technical and organizational measures to ensure the security of personal data:
encrypted communications (HTTPS),
access controls,
password management,
backups,
confidentiality agreements,
periodic supplier evaluations.
9. Third-Party Data
If the user provides third-party data (e.g., passengers), they guarantee:
that they have authorization or legitimacy,
that they have informed them of this Privacy Policy,
and that the data is accurate and up-to-date.
10. Changes to the Privacy Policy
The policy may be updated due to legal changes or service improvements.
The current version will always be published on this page.
1. Identity of the Data Controller
In compliance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), the user is informed that the personal data collected through the website https://www.justflyexecutive.com will be processed by:
Controller: LEARNBROKERS SL
Trade Name: Just Fly Executive
CIF: B55230890
Contact Email: info@justflyexecutive.com
Data Protection Officer (DPO) or equivalent contact: rgpd@justflyexecutive.com
2. What Personal Data Do We Process?
We collect only data that is adequate, relevant, and limited to what is necessary for each purpose. We may process:
2.1. Data Provided by the User:
Full Name
Phone Number
Email Address
Message or information included in forms
Billing information (if applicable)
Information necessary to provide private or charter flight services
Marketing Preferences
2.2. Data Generated by Browsing:
IP Address
Device Identifiers
Website Usage Data
Technical, personalization cookies, and, if the user consents, analytical cookies (Google Analytics).
For more information, please refer to the Cookies Policy.
2.3. Data Derived from the Service:
Request History
Information necessary to manage bookings or quotes
Contact details of passengers authorized by the client (if applicable)
3. Purposes and Legal Bases for Processing
3.1. Management of Inquiries, Quote Requests, or Contact
Purpose: To respond to requests made via form, email, or phone.
Legal Basis: User Consent (art. 6.1.a GDPR) and application of pre-contractual measures (art. 6.1.b GDPR).
3.2. Provision of Private Flight Services / Brokerage
Purpose: To manage reservations, contracts, and communications with the client.
Legal Basis: Performance of the contract (art. 6.1.b GDPR).
3.3. Communications Necessary for Service Provision
Purpose: Sending notices, incidents, contractual documentation, or operational information.
Legal Basis: Performance of the contract.
3.4. Commercial Communications (Marketing)
Purpose: Sending information about services, promotions, or offers.
Legal Basis:
User Consent (art. 6.1.a GDPR).
Legitimate Interest for past clients (art. 6.1.f GDPR), in accordance with art. 21.2 LSSI (soft opt-in).
3.5. Web Analytics
Purpose: To measure user interaction and improve the website using Google Analytics.
Legal Basis: User Consent (art. 6.1.a GDPR).
Analytical cookies are installed only when the user accepts them.
3.6. Compliance with Legal Obligations
Purpose: To meet tax, accounting, or regulatory requirements.
Legal Basis: Legal Obligation (art. 6.1.c GDPR).
4. How Long Do We Retain Data?
Type of Data | Duration |
|---|---|
Contact / Form Data | 12 months |
Client Data | Throughout the contractual relationship |
Accounting or Tax Obligations | 6 years (Commercial Code) |
Commercial Communications | Until consent is withdrawn |
Cookies | As specified in the Cookies Policy |
The data will be deleted or anonymized when no longer necessary.
5. To Whom Do We Disclose Data?
We do not sell or transfer data to third parties.
We may disclose data only to:
Essential providers for service provision (air operators, handling companies, ground transport, etc.).
Technology providers (hosting, email, CRM, analytics).
Legal Obligations (Tax Authorities, courts, or public agencies if necessary).
Google LLC, when the user accepts analytical cookies.
All operate under data processing contracts as per art. 28 GDPR.
6. International Data Transfers
The use of Google Analytics may entail transfers to the USA or third countries.
Google applies:
Standard Contractual Clauses (SCC),
complementary security measures,
and processing subject to GDPR.
The user can consult details in Google's official documentation.
7. User Rights
The user may exercise the following rights:
Right to Access
Right to Rectification
Right to Erasure
Right to Restriction
Right to Object
Right to Portability
Right to Withdraw Consent
Right to Not Be Subject to Automated Decisions
To exercise them:
📧 rgpd@justflyexecutive.com
(Attach a copy of an identification document if necessary.)
The user may also file a complaint with the supervisory authority:
Spanish Data Protection Agency (AEPD) — www.aepd.es
8. Data Security
LEARNBROKERS SL applies appropriate technical and organizational measures to ensure the security of personal data:
encrypted communications (HTTPS),
access controls,
password management,
backups,
confidentiality agreements,
periodic supplier evaluations.
9. Third-Party Data
If the user provides third-party data (e.g., passengers), they guarantee:
that they have authorization or legitimacy,
that they have informed them of this Privacy Policy,
and that the data is accurate and up-to-date.
10. Changes to the Privacy Policy
The policy may be updated due to legal changes or service improvements.
The current version will always be published on this page.