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 of our physical address is made in accordance with federal law, including the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act.

For any privacy-related questions, concerns, or to exercise your data protection rights, you may contact us directly via email at: legal@tlcjet.com. Providing clear and accessible contact information is a fundamental component of our commitment to transparency and is required by numerous data protection laws, including Florida's Information Protection Act (FIPA) and the General Data Protection Regulation (GDPR).

Applicability of This Policy

This Privacy Policy applies to all individuals ("users," "you," or "your") who access, browse, or use our website, including any subdomains and any other services we offer that link to this policy (collectively, our "Services"). It governs our practices for collecting, using, maintaining, protecting, and disclosing your personal data.

Our operations are based in the United States, but our Services are available to users worldwide. Consequently, this policy is designed to meet the rigorous standards of major international and domestic data protection frameworks. We are committed to protecting the privacy rights of all our users, regardless of their geographical location. For users located in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland, we adhere to the principles and requirements of the General Data Protection Regulation (GDPR). This global approach ensures a high standard of data protection for everyone who interacts with our Services.

Our Commitment to Your Privacy

TLC Jet is fundamentally committed to protecting your personal data and upholding your privacy rights. This policy has been drafted to be comprehensive, transparent, and written in clear, plain language. Our goal is to empower you with a thorough understanding of our data practices, the rights you possess concerning your data, and how you can exercise those rights. We believe that building trust begins with transparent and ethical data stewardship.

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

This section details the categories of personal data we collect, the purposes for which we use it, and the legal justification for our processing activities. This transparency is a cornerstone of modern privacy laws, including the GDPR and the Florida Digital Bill of Rights (FDBR).

Data You Provide to Us Directly

When you interact with our Services, such as by filling out a lead generation form, requesting a quote for a charter flight, subscribing to our communications, or otherwise contacting us, you may provide us with certain personal data directly. This information includes:

  • Contact Information: Your first and last name, email address, and telephone number.

  • Inquiry Details: Information pertinent to your travel needs, such as your desired flight routes, travel dates, number of passengers, and any specific service requests.

  • Communications: The content of any messages, feedback, or inquiries you send to us via email or our website's contact forms.

This information is collected for the primary purpose of responding to your requests, providing you with accurate and timely quotes, communicating with you about our services, and taking the necessary steps to fulfill our potential or existing contractual obligations to you.

Data We Collect Automatically

As you navigate and interact with our website, we may employ automatic data collection technologies, such as server logs and cookies, to gather certain technical and usage information about your device and browsing activities. This information helps us improve our website, maintain security, and provide a better user experience. The data collected automatically includes:

  • Log Files and Device Information: Your Internet Protocol (IP) address, browser type and version, Internet Service Provider (ISP), operating system, device identifiers, and other similar technical data.

  • Usage Details: Information about your interaction with our Services, such as the pages you visit, the date and time of your visit, the duration of your time on those pages, referring and exit pages, and clickstream data.

This data is used for analyzing website performance and user engagement, administering the site, detecting and preventing security threats, and optimizing our Services' functionality. This processing is essential for the secure and efficient operation of our online presence.

Lawful Basis for Processing

Under the GDPR and other modern data privacy laws, we only process your personal data when we have a valid legal reason, or "lawful basis," to do so. Our processing activities rely on the following lawful bases:

  • Consent: We process your personal data for specific purposes when you have given us clear, affirmative consent. The most prominent example is for sending you direct marketing communications via email or SMS. This consent must be freely given, specific, informed, and unambiguous.

  • Contractual Necessity: We process your personal data when it is necessary for the performance of a contract to which you are a party (e.g., arranging a charter flight you have booked) or to take steps at your request prior to entering into a contract (e.g., preparing and delivering a quote based on your inquiry).

  • Legitimate Interests: We process your personal data when it is necessary for our legitimate business interests, provided that these interests are not overridden by your own interests and fundamental rights. Our legitimate interests include operating and improving our website, ensuring the security of our IT systems, preventing fraud, maintaining business records, and, in some limited circumstances, conducting direct marketing to existing customers as permitted by applicable law.

A critical distinction exists between these bases. When you provide your contact information to request a quote, we process that data based on Contractual Necessity. This action, by itself, does not constitute consent to receive marketing materials. Sending marketing communications is a separate processing activity that requires your explicit Consent, which we request through a separate, specific opt-in mechanism.

Table 1: Summary of Data Processing Activities

To provide maximum clarity, the following table summarizes our data processing activities, linking the type of data we collect to its purpose and the corresponding lawful basis for processing under the GDPR.

Data Category

Source of Collection

Purpose of Processing

Lawful Basis (under GDPR)

Contact Information (Name, Email, Phone Number)

Provided by you via web forms or direct contact.

To respond to your inquiries, provide requested quotes, and deliver customer service.

Contractual Necessity (for service-related communication)

   

To send you promotional and marketing communications about our services.

Consent (obtained via explicit opt-in)

Travel Inquiry Details (Routes, Dates, Passengers)

Provided by you via web forms or direct contact.

To prepare and provide accurate service quotes and arrange charter services.

Contractual Necessity

Communications Content (Emails, Form Submissions)

Provided by you via email or web forms.

To provide effective customer service, resolve issues, and maintain accurate business records.

Legitimate Interest (to provide high-quality service and maintain operational records)

Technical & Usage Data (IP Address, Browser Type, Usage Patterns)

Collected automatically via server logs and strictly necessary cookies.

To ensure the proper functioning of our website, maintain security, prevent fraud, and conduct basic performance analysis.

Legitimate Interest (to operate a secure, stable, and efficient website)

Marketing & Analytics Data (From non-essential cookies)

Collected automatically via analytics and marketing cookies.

To understand user behavior, personalize website content, measure advertising campaign effectiveness, and deliver targeted ads.

Consent (obtained via our cookie consent banner)

 

III. Cookies and Tracking Technologies

 

Our website uses cookies and similar tracking technologies to enhance user experience, ensure functionality, analyze performance, and support our marketing efforts. This section provides a detailed and transparent explanation of our use of these technologies, in line with the requirements of the GDPR and the ePrivacy Directive.

What Are Cookies?

Cookies are small text files that are downloaded to your computer or mobile device when you visit a website. They store information about your visit and preferences, allowing the website to recognize you on subsequent visits and provide a more personalized experience. Cookies can be categorized by their lifespan and origin:

  • Session Cookies: These are temporary and are deleted from your device as soon as you close your web browser. They are used to maintain your state during a single browsing session, such as remembering what you've entered into a form.

  • Persistent Cookies: These remain on your device for a pre-defined period or until you manually delete them. They are used to remember your preferences and settings across multiple sessions, such as your language choice or login information.

  • First-Party Cookies: These are set directly by our website (the domain you are visiting). They are primarily used for core website functionality and analytics.

  • Third-Party Cookies: These are set by a domain other than our own. They are typically used for cross-site tracking, advertising, and analytics services provided by our partners, such as Google or Meta.

How We Use Cookies

To provide you with transparency and control, we classify the cookies used on our website into the following categories:

  • Strictly Necessary Cookies: These cookies are essential for the basic operation of our website and cannot be disabled in our systems. They are typically set in response to actions made by you which amount to a request for services, such as setting your privacy preferences or ensuring secure access. These cookies do not store any personally identifiable information and do not require your consent, though we must inform you of their use.

  • Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization. For example, they may be used to remember your preferred language or region. If you do not allow these cookies, some of our services may not function properly.

  • Performance and Analytics Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. We primarily use services like Google Analytics for this purpose.

  • Marketing and Targeting Cookies: These cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device.

Your Consent and Choices

Your privacy is paramount. In compliance with GDPR and other applicable laws, we will not place any non-essential cookies (i.e., Functional, Performance, or Marketing cookies) on your device without your explicit, affirmative consent.

When you first visit our website, you will be greeted by a cookie consent banner that provides clear choices regarding cookie usage. The design and functionality of this banner are guided by legal requirements to ensure your choice is freely given:

  • Clear and Equal Choices: The banner will present options to "Accept All," "Reject All," and "Customize" your preferences. The "Accept All" and "Reject All" buttons will be given equal prominence in size, color, and placement, ensuring it is as easy to refuse consent as it is to grant it. This practice avoids "dark patterns" that might nudge you into accepting.

  • Opt-In by Default: If you select the "Customize" option, you will see that all non-essential cookie categories are disabled by default. You must actively toggle them on to provide your consent.

  • Withdraw Consent at Any Time: You can change your preferences or withdraw your consent at any time with the same ease with which you gave it. A persistent and easily accessible link or icon (e.g., a "Cookie Settings" link in the website footer) will be available for you to manage your choices.

Table 2: Summary of Cookies Deployed on Our Website

The following table provides more detail on the categories of cookies we use, the services that may place them, and their purpose.

Cookie Category

Provider(s) / Service(s)

Purpose

Type & Typical Duration

Strictly Necessary

TLC Jet, LLC; Cloudflare; Google; Hubspot

Website security, core functionality, load balancing, and fraud prevention.

Session / Persistent (as needed for security)

Functional

TLC Jet, LLC

To remember user preferences such as language or region for a customized experience.

Persistent (e.g., up to 1 year)

Performance/Analytics

Google Analytics

To collect aggregated, anonymous data on website traffic and user interaction, helping us improve our Services.

Persistent (e.g., up to 2 years)

Marketing/Targeting

Google Ads, Meta (Facebook/Instagram), LinkedIn Ads

To track browsing activity across websites, build a profile of your interests, and display relevant advertisements on other platforms.

Persistent (e.g., 90-180 days)

 

IV. Marketing Communications: Email and SMS

This section outlines our policies for communicating with you for marketing purposes, ensuring full compliance with the U.S. Telephone Consumer Protection Act (TCPA), the CAN-SPAM Act, and Florida's specific and stringent Florida Telephone Solicitation Act (FTSA).

Our Marketing Philosophy

We aim to provide you with valuable information regarding our private jet charter services, special offers, empty leg flights, and other news that may be of interest. However, we are committed to a permission-based marketing model. We will only contact you for promotional purposes if you have explicitly asked us to, and we will always make it easy for you to stop receiving these communications.

Consent for Marketing Communications

We will only send you marketing communications via email or SMS text message if you have provided your prior express written consent. This is the highest standard of consent and is required to ensure compliance across all applicable regulations.

Your consent will be obtained through a clear, conspicuous, and unambiguous disclosure on our website, typically on our lead capture or contact forms. To opt-in, you must take an affirmative action, such as checking an unticked box. We will use separate checkboxes for email and SMS consent, so you can choose your preferred communication channels.

The consent disclosure will clearly and conspicuously state the following:

  • That by checking the box and submitting your information, you are providing your signature and agreeing to receive recurring automated marketing messages from TLC Jet, LLC at the email address or phone number provided.

  • For SMS messages, that they may be sent using an "automated system for the selection and dialing of telephone numbers" or similar technology, as defined by the TCPA and FTSA.

  • That your consent to receive marketing messages is not a condition of purchasing any property, goods, or services from us.

  • The expected message frequency (e.g., "Message frequency varies") and that "Message and data rates may apply".

  • A direct link to this Privacy Policy and our Terms of Service for your review.

How to Opt-Out of Marketing

You have the absolute right to withdraw your consent and opt-out of our marketing communications at any time, free of charge and without any hassle.

  • To Opt-Out of Email Marketing: You can opt-out by clicking the prominent "Unsubscribe" link that is included in the footer of every marketing email we send. Alternatively, you may email us at legal@tlcjet.com and request to be removed from our marketing email list.1

  • To Opt-Out of SMS Marketing: You can opt-out at any time by replying with the word "STOP" to any marketing text message you receive from us. You may also email us at legal@tlcjet.com with your phone number and a request to be unsubscribed from our SMS marketing list. Other standard keywords like "UNSUBSCRIBE," "CANCEL," or "QUIT" will also be honored.

We will process all opt-out requests promptly. In accordance with the CAN-SPAM Act, requests will be honored within 10 business days of receipt, though our systems are designed to process them much faster, often instantly. Once you have opted out, you will not be re-subscribed without a new, explicit request from you. Your contact information will be moved to a "suppression list" to ensure we honor your request.

Special Notice for Florida Residents (FTSA)

The Florida Telephone Solicitation Act (FTSA) includes specific provisions regarding consumer rights and legal action. Under a 2023 amendment to the FTSA, before a called party may file a lawsuit for receiving an unwanted text message, they must first notify the sender that they do not wish to receive further messages by replying "STOP" to the number from which the message was received. The sender then has a 15-day "cure period" to cease all text message communications to that number. A lawsuit may only be filed if the sender sends another text message after this 15-day period has expired. This notice serves to inform you of this legal prerequisite under Florida law.

V. How and Why We Share Your Personal Data

TLC Jet, LLC does not sell your personal data. We only share your information with third parties in limited circumstances, as described below, to operate our business, provide our Services, and comply with legal obligations.

Third-Party Service Providers (Data Processors)

We engage trusted third-party companies and individuals to perform services on our behalf and to assist us in operating our business. These service providers act as "data processors" and are given access to your personal data only to perform specific tasks under our instruction. They are bound by strict contractual obligations to maintain the confidentiality and security of your data. This includes requirements under both FIPA and GDPR.

Examples of the categories of service providers we use include:

  • Customer Relationship Management (CRM) and Marketing Automation Platforms: To manage our leads, customer interactions, and marketing campaigns. Examples of such platforms include HubSpot and Salesforce.

  • Cloud Hosting and Infrastructure Providers: To host our website and store our data securely.

  • Email and Communication Service Providers: To facilitate sending emails and SMS messages.

  • Analytics Providers: To help us understand the usage of our Services.

We conduct due diligence on our vendors to ensure they have appropriate security and privacy practices in place. We execute Data Processing Agreements (DPAs) with these vendors where required by law, which contractually obligate them to protect your data to the standards required by this policy and applicable regulations.

 

Legal Obligations and Safety

 

We may disclose your personal data if we believe in good faith that such disclosure is necessary to:

  • Comply with a legal obligation, court order, subpoena, or other lawful request from public authorities.

  • Protect and defend the rights, property, or safety of TLC Jet, LLC, our customers, or the public.

  • Prevent or investigate possible wrongdoing in connection with the Services.

  • Enforce our legal agreements, including our Terms of Service.

 

Business Transfers

 

In the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TLC Jet's assets, your personal data may be among the assets transferred. We will ensure that the receiving party agrees to respect your personal data in a manner that is consistent with this Privacy Policy.

 

Third-Party Website Links

 

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. The inclusion of such links does not imply an endorsement of the linked site or its content.

 

VI. Your Data Protection Rights

 

We are committed to ensuring you can exercise your data protection rights easily and effectively. This section outlines the rights available to you, which are derived from comprehensive data protection laws like the GDPR and the Florida Digital Bill of Rights (FDBR).

 

Your Comprehensive Rights

 

Depending on your location and subject to applicable law, you may have the following rights with respect to your personal data:

  • The Right to Be Informed: The right to receive clear, transparent, and easily understandable information about how we process your personal data. This Privacy Policy is our primary means of fulfilling this right.

  • The Right of Access: The right to request and obtain a copy of the personal data we hold about you, along with information about how we are processing it.

  • The Right to Rectification (Correction): The right to have any inaccurate or incomplete personal data we hold about you corrected without undue delay.

  • The Right to Erasure (Right to be Forgotten): The right to request the deletion of your personal data where there is no compelling reason for us to keep using it. This right is not absolute and only applies in certain circumstances.

  • The Right to Restrict Processing: The right to 'block' or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your data, but may not use it further.

  • The Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and the right to transmit that data to another controller.

  • The Right to Object: The right to object to our processing of your personal data where it is based on our legitimate interests. You have an absolute right to object to your data being used for direct marketing purposes.

  • The Right to Opt-Out of Sales and Certain Profiling: The right to opt-out of the "sale" of your personal data and the processing of your data for purposes of targeted advertising or certain types of profiling. (Note: TLC Jet does not "sell" personal data in the traditional sense).

  • Rights Related to Automated Decision-Making: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you.

 

How to Exercise Your Rights

 

To exercise any of the rights described above, please submit a verifiable request to us by emailing legal@tlcjet.com.

To protect your privacy and security, we may need to take reasonable steps to verify your identity before processing your request. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request.

 

Response Timeline and Process

 

We will respond to your request without undue delay. In accordance with the FDBR and in alignment with GDPR timelines, we will respond within 45 days of receiving your request. This period may be extended once by an additional 15 days where reasonably necessary, taking into account the complexity and number of requests. We will inform you of any such extension within the initial 45-day period, along with the reasons for the delay.11

 

Right to Appeal

 

If we decline to take action on your request, we will inform you of our decision and the reasons for it. Under the FDBR, you have the right to appeal our decision. We will provide you with instructions on how to submit an appeal in our response.

 

Non-Discrimination

 

We will not discriminate against you for exercising any of your data protection rights. This means we will not deny you services, charge you different prices or rates, or provide you with a different level or quality of service simply because you have exercised your rights.

 

VII. International Data Transfers

 

As a U.S.-based company with a global user base, personal data we collect may be transferred to, stored, and processed in the United States, a country that may not have data protection laws equivalent to those in your jurisdiction (such as the EEA, UK, or Switzerland). We are committed to ensuring that your personal data receives an adequate level of protection wherever it is processed.

 

Safeguards for International Transfers

 

When we transfer personal data from the EEA, UK, or Switzerland to countries that have not been deemed to provide an adequate level of data protection by the European Commission, we rely on appropriate legal safeguards to protect the data.

Our primary mechanism for such transfers is the use of Standard Contractual Clauses (SCCs). SCCs are pre-approved model data protection clauses adopted by the European Commission. When incorporated into a contract between a data exporter (like an EU-based partner) and a data importer (like TLC Jet in the U.S.), they create a binding legal agreement that requires the data importer to adhere to EU-level data protection standards. We use the relevant modules of the 2021 SCCs for our data transfer activities, such as for controller-to-processor transfers with our European vendors.

In addition to SCCs, we conduct Transfer Impact Assessments (TIAs) as required. A TIA is a risk assessment that evaluates the laws and practices of the destination country (the U.S.) to ensure that the SCCs can be effectively complied with in practice. This assessment helps us implement any supplementary measures necessary to ensure your data remains protected to an EU standard.

By implementing these safeguards, we ensure that your personal data is protected with the same high standards of security and confidentiality, regardless of where it is processed.

 

VIII. Data Security and Retention

 

 

Our Data Security Measures

 

We take the security of your personal data very seriously. In compliance with the Florida Information Protection Act (FIPA) and global best practices, we have implemented and maintain reasonable administrative, physical, and technical safeguards designed to protect the confidentiality, integrity, and availability of your personal data from unauthorized access, use, disclosure, alteration, or destruction.43

Our security measures include, but are not limited to:

  • Encryption: We use encryption technologies like Transport Layer Security (TLS) to protect data in transit (e.g., when you submit a form on our website). Sensitive data at rest is also encrypted.

  • Access Controls: Access to personal data is restricted on a "need-to-know" basis. We use role-based access controls (RBAC) to ensure that employees and authorized personnel can only access the data necessary to perform their job functions.

  • Regular Security Assessments: We conduct regular risk assessments and vulnerability monitoring to identify and mitigate potential threats to our data protection infrastructure.

  • Incident Response Plan: We have established a detailed plan to respond effectively in the event of a data breach, including procedures for investigation, mitigation, and notification.

  • Employee Training: Our employees are trained on data security best practices and their responsibilities in protecting customer data.

While we take extensive measures to protect your data, no security system is impenetrable. The transmission of information via the internet is not completely secure, and we cannot guarantee the absolute security of your personal data. Any transmission is at your own risk.

 

Our Data Retention Policy

 

We adhere to the principles of data minimization and purpose limitation. This means we will retain your personal data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Our general data retention schedule is as follows:

  • Lead and Marketing Data: Personal data collected for lead generation and marketing purposes (e.g., from web forms where consent for marketing was given) will be retained for 2 years from the date of our last meaningful contact with you, unless you withdraw your consent earlier.

  • Customer and Contractual Records: Data related to our customers and the services we provide, including contracts and financial records, will be retained for 7 years after the end of the customer relationship to comply with legal and tax obligations.

  • Opt-Out/Suppression Lists: If you opt-out of marketing communications, we will retain the minimum necessary information (e.g., your email address or phone number) on a suppression list indefinitely to ensure we can honor your request and prevent future marketing communications.

  • Website Analytics Data: Aggregated and anonymized analytics data may be retained for up to 2 years for trend analysis and service improvement.

  • Legal Holds: Notwithstanding the above, we may retain data for longer periods if it is subject to a legal hold or is necessary for litigation, investigation, or regulatory proceedings.

Once the retention period expires, we will securely delete or anonymize your personal data in accordance with our data disposal procedures.

 

IX. Children's Privacy

 

Our Services are not intended for or directed at children. We are committed to complying with the Children's Online Privacy Protection Act (COPPA) and other applicable laws protecting the privacy of minors.

 

Age Limitations

 

We do not knowingly collect, use, or disclose personal information from children under the age of 13. The Florida Digital Bill of Rights extends certain protections to all minors under the age of 18. Therefore, as a matter of policy, we do not knowingly collect personal data from any individual under the age of 18.

If we learn that we have inadvertently collected personal information from a child under 18 without verification of parental consent, we will take immediate steps to delete that information from our records as quickly as possible.

 

Information for Parents

 

If you are a parent or guardian and you believe that your child has provided us with personal information without your consent, please contact us immediately at legal@tlcjet.com. We will work with you to promptly delete your child's information from our systems.

 

X. "Do Not Track" Signals

 

Some web browsers offer a "Do Not Track" ("DNT") feature, which sends a signal to websites you visit indicating that you do not wish to be tracked. This section discloses our policy regarding these signals, as required by the California Online Privacy Protection Act (CalOPPA).

 

Our Response to DNT Signals

 

Currently, there is no universally accepted industry standard for how to recognize, interpret, and respond to DNT signals. Consequently, like most websites, TLC Jet, LLC does not currently alter its practices when it receives a DNT signal from a visitor's browser.

We do not respond to DNT signals because we cannot guarantee that all third-party services integrated into our website (such as analytics providers or advertising networks) will honor DNT requests. To provide a consistent and transparent experience, our policy is to disclose our practices and provide you with direct control over your data through the mechanisms described in this Privacy Policy, such as our cookie consent manager and marketing opt-out options.73

 

XI. Data Breach Notification Procedures

 

In the unfortunate event of a data breach involving your personal information, we are prepared to act swiftly to mitigate the impact and notify affected parties and regulatory authorities in accordance with our legal obligations under laws such as the Florida Information Protection Act (FIPA) and the GDPR.

 

Our Commitment

 

We have established a formal Incident Response Plan to ensure a timely and effective response to any security incident. Our commitment is to promptly investigate the incident, take remedial measures, and provide transparent notification.

 

Notification Under the Florida Information Protection Act (FIPA)

 

For any breach of security affecting the personal information of Florida residents, we will adhere to the following stringent notification requirements as mandated by FIPA 43:

  • Notice to Affected Individuals: We will provide written notice to all affected Florida residents as expeditiously as practicable, and no later than 30 days after our determination that a breach has occurred. This notice will be sent to the most recent address we have on file for the individual, which may be a physical or email address.

  • Notice to the Florida Department of Legal Affairs: If a breach affects 500 or more Florida residents, we will also provide written notice to the Florida Department of Legal Affairs no later than 30 days after the determination of the breach.

  • Notice to Consumer Reporting Agencies: If a breach affects 1,000 or more Florida residents, we will provide notice to all nationwide consumer reporting agencies without unreasonable delay.

 

Notification Under GDPR

 

For any breach affecting the personal data of individuals in the EEA or UK that is likely to result in a risk to their rights and freedoms, we will notify the relevant data protection supervisory authority without undue delay, and where feasible, not later than 72 hours after having become aware of it.

 

Content of the Notification

 

Our notification to you will be clear and will include, at a minimum:

  • The nature of the data breach, including the approximate date or date range of the incident.

  • A description of the categories of personal information that were compromised.

  • The steps we are taking to address the breach and mitigate potential harm.

  • Information you can use to contact us to inquire further about the breach and the personal information we hold about you.

 

Third-Party Vendor Breaches

 

Our contracts require our third-party service providers to notify us of any data breach affecting our data as expeditiously as practicable. Under FIPA, this notification from a third-party agent must occur no later than 10 days following their determination of the breach, allowing us to meet our own notification deadlines.

 

XII. Governing Law and Dispute Resolution

 

 

Governing Law

 

This Privacy Policy and any dispute, claim, or controversy arising out of or relating to it or its subject matter shall be governed by and construed in accordance with the laws of the State of Florida, United States of America, without giving effect to any choice or conflict of law provision or rule.

 

Dispute Resolution

 

We are committed to resolving any concerns you may have about your privacy. We encourage you to contact us first at legal@tlcjet.com to allow us an opportunity to resolve your concerns directly.

Should we be unable to resolve a dispute amicably through informal negotiations, you and TLC Jet, LLC agree that any claim, dispute, or controversy arising out of or relating to this Privacy Policy shall be resolved through final and binding arbitration.

  • Arbitration Agreement: Any dispute, claim or controversy arising out of or relating to this Agreement or the breach, termination, enforcement, interpretation or validity thereof, including the determination of the scope or applicability of this agreement to arbitrate, shall be determined by arbitration in Broward County, Florida before one arbitrator. The arbitration shall be administered by JAMS pursuant to its Comprehensive Arbitration Rules and Procedures. Judgment on the Award may be entered in any court having jurisdiction. This clause shall not preclude parties from seeking provisional remedies in aid of arbitration from a court of appropriate jurisdiction.

  • Class Action Waiver: You and TLC Jet, LLC agree that any arbitration will be conducted in your respective individual capacities only and not as a class action or other representative action, and you and TLC Jet, LLC expressly waive your respective right to file a class action or seek relief on a class basis.

  • Confidentiality: The parties shall maintain the confidential nature of the arbitration proceeding and the Award, including the Hearing, except as may be necessary to prepare for or conduct the arbitration hearing on the merits, or except as may be necessary in connection with a court application for a preliminary remedy, a judicial challenge to an Award or its enforcement, or unless otherwise required by law or judicial decision.

 

XIII. Accessibility Statement

 

 

Our Commitment to Accessibility

 

TLC Jet, LLC is committed to ensuring that our website and its content, including this Privacy Policy, are accessible to all users, including people with disabilities. We are continually improving the user experience for everyone and striving to apply the relevant accessibility standards, such as the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA.

 

Feedback and Assistance

 

We welcome your feedback on the accessibility of our Services. If you encounter any accessibility barriers or have difficulty accessing any information on our website, please let us know. We will work with you to provide the information you need through an alternative communication method or to make the necessary improvements.

Please contact us at legal@tlcjet.com with "Accessibility" in the subject line and provide a description of the specific feature you feel is not fully accessible or a suggestion for improvement.80

 

XIV. Changes to Our Privacy Policy

 

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this policy, we will post the updated notice on our website and update the policy's "Last Updated" date at the top of this page.

Your continued use of our Services following the posting of changes constitutes your acceptance of such changes. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. For material changes, we may provide more prominent notice, such as through an email notification or a banner on our website.

Plane