Privacy Charter

This is version 1.0, and is considered active as of December 18, 2022 12:00 AM.

Who are 'we'?

We're Volanti.Aero Limited t/a Split My Flight ("we", "our", "us") and operate under the names "Volanti", "Volanti.aero", and "Split My Flight".

We're registered with the UK data protection authority (the Information Commissioner's Office, or ICO) under number ZB313867.

This charter details how and why we use your personal information when you open a Split My Flight account, use our platform, or any of our related services.

If you require additional details about something in this notice, or want to speak to us with regard to data protection, you can email us at [email protected].

The information we hold as a controller, and how we use it 🗂

When you sign up for a Split My Flight account

  • Personal details of you
  • Contact details of you
  • Information about your aviation related license(s)

When you get in touch

Depending on the mechanism you use to contact us, we may collect the following:

  • Your email address you use and the contents of the email, along with any attachments
  • The phone number you're calling from and any details you give us during the call
  • Public details from your social media profile (like Facebook, Instagram, or Twitter) if you reach out via them

Information we collect or generate when you use our platform

We collect information about actions taken within the platform, for security and auditing purposes. These details contain data relating to the user who carried out the behaviour, along with metadata relating to the activity. For example, where you record that you have signed an agreement, created a flight, or downloaded a compliance document, we will store details of your browser and internet connection as a digital fingerprint.

Information we get from external sources

For further details about data we collect from and share with external companies, see "who we share your data with" below.

As part of our ongoing KYB and AML checks, we may use public sources or market research, such as official public records, Electoral registers, Companies House, or information published by the press and social media.

The information we hold as a processor, and how we use it ⚙️

We process user (passenger) data on your behalf, at your request. We do so as a processor and beyond guiding you on what data collection should take place to facilitate the smooth operating of your flights, you remain in control of it.

When you enter passenger details

  • Their name
  • Their email address
  • Details about their browser when they sign an agreement
  • Their signature/identity mark

Reasons for using your information 👩‍⚖️

Data protection laws state that we must have a lawful basis for using your personal data. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest, or consent.

We categorise our data usage in a number of ways - this means that for different businesses cases, different lawful basis may apply. These categories are as follows:

When it's in our legitimate interest to do so. This means that we'll use your data for legitimate purposes in line with our business, in the way that you'd expect, that is in the interest of you and/or us and/or a third party. This will never involve eroding your personal right to privacy.

To fulfil a contract with you, or enter into a contract with you. This means that we use the data to:

  • provide the service to which you have subscribed
  • send messages and notifications about your account whether you initiate the conversation, or we do
  • investigate complaints

For product development, marketing, and research. As a technology company we always look to improve our business processes and our platform. Your data may help us to do that, by:

  • allowing us to tell you about products, services, and features that we offer, via any of our main communication channels, or via advertising partners
  • excluding you from specific advertising campaigns, to ensure our marketing reaches the intended audiences
  • providing additional information about features or services you are interested in, along with any information you willingly provide to us to express your interest
  • sharing insights, trends, metrics, and statistics of platform usage and user engagement, without personally identifying you.

It's important to reiterate, we will never sell your data.

Where we need to comply with the law which may be as simple as confirming your identity, right up to complying with a legal obligation. Examples of these scenarios include:

  • confirming your identity when you sign up to the platform, or we are instructed to by any organisation on the platform
  • prevent illegal activities
  • keep your information inline with our legal obligations for accurate record keeping

For security. We take this incredibly seriously, but to make our platform secure, we sometimes need to use your data:

  • to protect the rights, or safety of us, our users, or your passengers
  • maintain the security of our platform and other services, ensuring we provide a good experience for you
  • when communicating with third parties that are providing services on our behalf (such as identity checks)

When working with third parties to provide an enhanced experience to you, or facilitating some features on the platform. You can read more about our data sharing partners further in this policy.

With your consent. It is, after all, your data. We'll ask for your implied or explicit consent before:

  • sharing your details with others on the platform
  • we share more fine-grained or non-aggregate details about your account with third parties, where we haven't outlined that usage in this policy
  • subscribe you to our mailing lists for the purpose of sharing platform updates

It's incredibly important to remember that whilst you can withdraw your consent to these situations at any time, the data may be covered by another lawful basis, and that if we stop processing your information, we may not be able to provide a service to you.

Our data sharing partners 🤝

Named Companies

Split My Flight partners with a number of companies that provide services to us. This could be companies related to the provision of the technical hardware and infrastructure that we operate from, or payment partners, for example. We will always share the minimum amount of information necessary to maintain the relationship we have with these organisations, and we will never sell your data to them. Where it's possible to share information with them without making you personally identifiable, we will do so.

These companies include:

Law enforcement

If the law requires us to share your information, we will comply. However, outside the affordances offered by these terms, we will only do so with a Government authority where we are compelled to do so.

In instances where organisations are in breach of our restricted usage policy, and their behaviour warrants reporting to the authorities, we will take action and pass the necessary details to aid with the investigation. Further, where we suspect cases of money laundering, crime, tax evasion, we have a moral duty to stop the proceeds of financial crime being transferred via our platform, and will report this to the necessary agencies.

Any other parties

Where you provide us written permission to do so, we will share your data with other parties. These companies may include:

  • providers of insurance, to whom you wish to make an inquiry
  • the relevant aviation authorities, to whom you wish us to provide documentation
  • other users of the platform, with whom you wish to communicate
  • people you've asked to represent you, such as solicitors
  • other platforms, if you wish to leave us and transfer your data

How long do we keep your information? 🗄️

We keep hold of your data, in a secure location, whilst you are an active user of Split My Flight. After you cease to be a user by closing your account, we will attempt to remove all personal data within 30 days (although it can take up to 90 days for your data to no longer exist within our backups).

Where your account has been terminated for breach of our terms, and we are liaising with external agencies due to the severity or nature of that breach, it is our legitimate interest to retain data for longer than specified within this document, for the safe and effective investigation of the situation.

Your rights 👀

The law bestows upon you some basic rights regarding your data:

  • The Right to Information: requires us to explain how and why we are processing your information
  • The Right of Access: which guarantees your ability to access the data we hold on you, or get a copy of it
  • The right to Rectification: mandates our requirement to correct inaccurate data after you notify us
  • The Right to Erasure: requires us to delete, or suppress, your data (although for legal reasons we might not always be able to comply)
  • The Right to Restriction of Processing: ask us to temporarily reduce the processing we carry out on your information
  • The Right to Data Portability: grants access to your data in a portable (machine-readable) format, or requires us to transmit it to someone else
  • The Right to Object: tell us 'no' for further processing for other legitimate interests
  • The Right to Avoid Automated Decision-Making: enables you to request a manual review of any automated decisions our platform makes using your data