Privacy Notice

Contact Information

Children

Changes to this Privacy Notice

Third Party Applications / Websites

Transmission of Data to other countries

How We Protect and Retain DatA

Your Choices

How We Share Data

How We Use Data

Data We Collect

This Privacy Notice (“Notice”) applies to personal data collected by Azorra Aviation Holdings, LLC and its corporate affiliates (collectively, “Azorra,” “we,” “us,” or “our”). This Notice also covers rights and choices related to your personal data. 

Contents: 


Privacy Notice

Here You will find our Website's Privacy Notice. 
You can find our website Terms And Conditions here.

Privacy Notice

We collect data about you in different ways. For example, we collect data:
  • Directly from you. This includes when you apply for employment with us, sign up to get our emails or contact us. 
  • Automatically. This includes through cookies, server logs, and other tools on our website. 
  • From other sources. These can include our affiliates, vendors, publicly available sources, and other companies. 

The following are a few examples of our collection and use of data: 

Data We Collect

Sensitive Information Disclosures.
We may collect the following categories of sensitive personal data (as defined under relevant laws) when you apply for a job with us: social security number (or national equivalent), driver’s license number, state identification card, or passport number; racial or ethnic origin, religious, or philosophical beliefs, or union membership; and information concerning health. We collect this data for many reasons, including: to manage our business, process your application; determine your eligibility for employment; conduct background checks (where permitted by applicable law); comply with applicable laws and regulations; verify customer information; and exercise or defend the legal rights of Azorra and its employees and affiliates, customers, contractors, and agents. Note that we do not use such data for any purposes that are not identified within Cal. Civ. Code § 1798.121. 

We do not “sell” or “share” sensitive personal data for cross-context behavioral advertising, although we may transfer it to third parties when you instruct us to do so. When that occurs, third parties will use it for the purposes indicated in their privacy notices.

If you are in Canada, our lawful basis for processing your data is generally consent. 

Context

Examples of Personal data

Primary Purpose & Legal Basis

Customer Information 

We collect the name and contact information of our customers and their employees with whom we may interact. 

We have a legitimate interest in contacting our customers and communicating with them about business activities such as projects, services, and billing.

Contacting Us

If you contact us, we collect your name and email, as well as other content that you send.

We have a legitimate interest in receiving and acting upon feedback.

Job Applicants

If you apply for a job or provide us with your personal information for purposes of employment, we collect information needed to process your application. This may include your government identification information (e.g. social security number or equivalent), contact information, citizenship information, demographic information (e.g. age), health information about your ability to perform a job with or without accommodation, and any information on your resume. Providing this information is required for employment.

Under some laws, we are required to collect and report certain demographic workforce data to federal, state
and/or local government agencies for civil rights enforcement purposes. This could include date of birth
and gender as well as more sensitive personal information including information relating to racial and ethnic origin, religious, political, or philosophical beliefs, and trade union membership. We may also ask you to voluntarily self-identify whether you belong to additional protected classes (disability status, sexual orientation, veteran status, etc).

In some contexts, we are required by law to collect data about applicants. We also have a legitimate interest in using data to evaluate your application or consider you for other positions. If you become an employee, we may provide you with a separate privacy notice that explains how we collect, use, and share additional data about our employees.

Know Your Customer (KYC)
Due Diligence

We collect personal information about our vendors, customers, trading partners and job applicants to conduct Know-Your-Customer due diligence screenings. 

This screening includes, but is not limited to, your: identifiers, citizenship, government issued identification, and other personal data. 

In some contexts, we are required by law to perform Know-Your-Customer due diligence measures to, among other things, identify if we are restricted in our dealings with certain individuals.

Use of Our Website

We use technology (e.g., a pixel) to learn how you engage with our websites. This may include which links you click or what you type into our online forms. We may also track your IP address, the website that referred you to us, and data about your device. 

We have a legitimate interest in making our website operate. We also use it to understand how you interact with our websites, gather analytics, improve our websites. We may also use this data to protect our website.

Sensitive Information Disclosures.
We may collect the following categories of sensitive personal data (as defined under relevant laws) when you apply for a job with us: social security number (or national equivalent), driver’s license number, state identification card, or passport number; racial or ethnic origin, religious, or philosophical beliefs, or union membership; and information concerning health. We collect this data for many reasons, including: to manage our business, process your application; determine your eligibility for employment; conduct background checks (where permitted by applicable law); comply with applicable laws and regulations; verify customer information; and exercise or defend the legal rights of Azorra and its employees and affiliates, customers, contractors, and agents. Note that we do not use such data for any purposes that are not identified within Cal. Civ. Code § 1798.121. 

We do not “sell” or “share” sensitive personal data for cross-context behavioral advertising, although we may transfer it to third parties when you instruct us to do so. When that occurs, third parties will use it for the purposes indicated in their privacy notices.

If you are in Canada, our lawful basis for processing your data is generally consent. 

We have a legitimate interest in making our website operate. We also use it to understand how you interact with our websites, gather analytics, improve our websites. We may also use this data to protect our website.

Primary Purpose & Legal Basis

We use technology (e.g., a pixel) to learn how you engage with our websites. This may include which links you click or what you type into our online forms. We may also track your IP address, the website that referred you to us, and data about your device. 

Examples of Personal data

Use of Our Website

Context:

In some contexts, we are required by law to perform Know-Your-Customer due diligence measures to, among other things, identify if we are restricted in our dealings with certain individuals.

Primary Purpose & Legal Basis

We collect personal information about our vendors, customers, trading partners and job applicants to conduct Know-Your-Customer due diligence screenings. 

This screening includes, but is not limited to, your: identifiers, citizenship, government issued identification, and other personal data. 

Examples of Personal data

Know Your Customer (KYC) Due Diligence

Context:

In some contexts, we are required by law to collect data about applicants. We also have a legitimate interest in using data to evaluate your application or consider you for other positions. If you become an employee, we may provide you with a separate privacy notice that explains how we collect, use, and share additional data about our employees.

Primary Purpose & Legal Basis

If you apply for a job or provide us with your personal information for purposes of employment, we collect information needed to process your application. This may include your government identification information (e.g. social security number or equivalent), contact information, citizenship information, demographic information (e.g. age), health information about your ability to perform a job with or without accommodation, and any information on your resume. Providing this information is required for employment.

Under some laws, we are required to collect and report certain demographic workforce data to federal, state and or local government agencies for civil rights enforcement purposes. This could include date of birth and gender as well as more sensitive personal information including information relating to racial and ethnic origin, religious, political, or philosophical beliefs, and trade union membership. We may also ask you to voluntarily self-identify whether you belong to additional protected classes (disability status, sexual orientation, veteran status, etc).

Examples of Personal data

Job Applicants

Context:

We have a legitimate interest in receiving and acting upon feedback.

Primary Purpose & Legal Basis

If you contact us, we collect your name and email, as well as other content that you send.

Examples of Personal data

Contacting Us

Context:

We have a legitimate interest in contacting our customers and communicating with them about business activities such as projects, services, and billing.

Primary Purpose & Legal Basis

We collect the name and contact information of our customers and their employees with whom we may interact. 

Examples of Personal data

Customer Information 

Context:

We also use data to: 
  • Identify you when you visit our sites. 
  • Complete transactions. 
  • Improve or create services and products.
  • Conduct analytics.
  • Connect with you (e.g., addressing your requests, inquiries, issues, or feedback). 
  • Market our products or services.
  • Find and prevent malicious, deceptive, fraudulent, or illegal activity.
  • Find and prevent security incidents. 
  • Enforce our policies and agreements.
  • Debug, find, and fix errors that impair our website and services.
  • Comply with legal or regulatory obligations. 
  • Establish or exercise our rights. 
  • Defend against legal claims.
  • Manage our relationships.
  • Conduct due diligence activities as part of our Know-Your-Customer (or “KYC”) procedures.
  • For other reasons with your consent.

The sections above describe our main purposes in collecting your data, but often we have multiple purposes. For example, if you send us an email asking for information we have a legitimate interest in responding to your request. We also may maintain a record of your email for context in case you contact us in the future. As a result, our collection and processing of your data is based in different contexts on your consent, our need to perform a contract, our legal obligations, and/or our legitimate interest in conducting our business.

How We Use Data

In addition to the specific situations discussed elsewhere in this Notice we may share personal data in the following situations: 
  • Affiliates and Acquisitions. We may share data with our affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If a company acquires or enters negotiations to acquire (either in-full or in-part), our company, business, or assets, we may share data with that company. 
  • Other Disclosures without Your Consent. We may share data to cooperate with law enforcement, participate in a legal process, or for legal compliance. We may share your data to establish or exercise our rights, to defend against legal claims, to investigate, prevent, or act on possible illegal activities, threats to safety of person or property, or a violation of our policies. Your data may be shared in order to deliver aircraft to you.
  • Service Providers. We share your data with service providers. Service providers help us to run our website, provide technical support, fulfill orders, conduct KYC, and more.
  • Professional Services. We may share personal data with our professional service providers, such as auditors or lawyers.
  • Other Disclosures with Your Consent. We may share your data with third parties when you consent or direct us to. 

Some areas require us to disclose whether the following categories of personal data are collected, shared with third parties for a “business purpose,” or “sold,” or transferred for “valuable consideration.” The table below indicates the categories of personal data we collect and transfer in a variety of contexts. We do not “sell” your personal data for money, and we do not engage in cross-context behavioral advertising. Because our services are not intended for children, we have no actual knowledge that we share for targeted advertising any personal data of individuals who are under 16 years of age.

How We Share Data

Additional categories of personal data described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Inferences drawn from any of the information listed above, such as profile or summary about a staff member's preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Non-public education information (as defined in the Family Educational Rights and Privacy Act).

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Professional or employment-related information – this includes, for example, information submitted by job applicants.

  • Affiliates or subsidiaries.
  • Operating systems and platforms.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Affiliates or subsidiaries.
  • Professional services organizations, this may include auditors and law firms.

Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Health Related Information – this may include medical information, mental or physical condition or treatment, or health insurance information.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Category of Personal Data

Disclosures for a Business Purpose

Category of Recipients

Identifiers – this may include things like name, alias, postal address, unique personal identifier, online identifier, or email address.

  • Affiliates or subsidiaries.
  • Internet service providers.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Financial institutions.
  • Professional services organizations, this may include auditors and law firms.

Government Issued Identification – this may include things like social security number, driver’s license number, or state issued identification number.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

Identifiers – this may include things like name, alias, postal address, unique personal identifier, online identifier, or email address.

  • Affiliates or subsidiaries.
  • Internet service providers.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Government Issued Identification – this may include things like social security number, driver’s license number, or state issued identification number.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Financial institutions.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Health Related Information – this may include medical information, mental or physical condition or treatment, or health insurance information.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Affiliates or subsidiaries.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Professional or employment-related information – this includes, for example, information submitted by job applicants.

  • Affiliates or subsidiaries.
  • Operating systems and platforms.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Non-public education information (as defined in the Family Educational Rights and Privacy Act).

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Inferences drawn from any of the information listed above, such as profile or summary about a staff member's preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Additional categories of personal data described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics, or description, insurance policy number.

  • Affiliates or subsidiaries.
  • Other Service Providers.
  • Professional services organizations, this may include auditors and law firms.

- Disclosures for a Business Purpose -

Category of Recipients

Category of Personal Data

Some jurisdictions give you a right to make the following choices:
  • Access. You may request access to your personal data or confirmation that we have data about you. In certain limited cases, you may ask to receive access to your data in a portable, machine-readable form. 
  • Deletion. You may ask us to delete your personal data. If required by law, we will grant such a request, but note that in many cases, we must keep your personal data to comply with legal obligations, resolve disputes, enforce agreements, or for other business purposes. 
  • Objection to or Restriction of Certain Processing. In certain circumstances, you may object to the processing of your personal data, or ask that we restrict processing of your personal data. To do so, follow the instructions below. 
  • Revocation Of Consent. Where we process your personal data based upon consent, you may revoke consent. Note, if you revoke consent for processing personal data, we may no longer be able to provide you some types of services. 

Not all the rights above are absolute, and they do not apply in all circumstances. We may limit or deny a request because the law permits or requires us to. We will not discriminate against individuals who exercise a privacy right.

Submitting Requests

You may exercise the above rights through our online form or by contacting us via the contact information below. 

We will require you to prove your identity when making most types of requests. We may verify your identity by email. In some cases we may ask you to send us a signed declaration confirming your identity.

In some circumstances, you may designate an authorized agent to exercise rights on your behalf. If you are an authorized agent, you must send us a copy of a completed Authorized Agent Designation Form to email address: DSR@azorra.com,  which shows that you may act on another’s behalf.

Your Choices

No method of internet transmission or electronic storage is fully secure. While we use reasonable efforts to protect personal data, we cannot guarantee its security. If we are required to inform you about a security incident, we will do so electronically, in writing, or by phone, as the law permits.

We keep your personal data for only as long as necessary to fulfil the purposes in this Notice unless a longer retention period is required or permitted by law. This includes the purposes of satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data. We also weigh the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we obtained the data and whether we can meet those purposes through other means, as well as applicable legal requirements.

How We Protect and Retain DatA

As a multi-national company, we send data between and among our affiliates. As a result, we may process your data in a country with less stringent privacy laws than the laws in the country that you reside. Where possible, we treat personal data using the same privacy principles that guide the law of the country in which we first receive your data. By submitting your personal data to us you agree to the transfer, storage, and processing of your data in a country other than your country of residence including, but not limited to, the United States. For more information on our attempts to apply the privacy principles applicable in one area to data when it goes to another, contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.

Transmission Of Data To Other Countries

We may provide links to websites and other third-party content or services that we do not own or operate. We have no control over the privacy practices of websites or services we do not own. For details about such third parties’ privacy practices, see their privacy notices.

Third-Party Applications/Websites

We may change our Notice and privacy practices. New notices will be published on our website. If changes are material, we will notify you on our website. Also, if changes are material, the Notice that was in place when you submitted personal data to us will generally govern that data unless you consent to the new Notice. Our Notice shows “effective” and “last updated” dates below. The effective date is the date the current version took effect. The last updated date is the date the current version was last substantively changed.

Changes To This Privacy Notice

Our websites and online services are not meant for children under 13 years old, and we do not knowingly collect personal data from children under age 16 without parental consent. Children under 13 should not give us their personal data.

Children

If you are not satisfied with our response and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

Email: socialmedia@azorra.com

Azorra Limited
25 Earlsfort Terrace,
First Floor
Dublin D2, D02 PX51
Ireland

In the European Union:

Email: socialmedia@azorra.com

Azorra Aviation Holdings, LLC 
201 East Las Olas Blvd., Suite 2250 
Fort Lauderdale, FL 33301 
United States

In the United States:

If you have questions, comments, or complaints on our privacy practices, or if you need to access this Notice in a different form due to a disability, please contact us. We will try to address your requests and provide you with additional privacy-related information. 

Contact Information

June 30, 2026

Last updated:

June 30, 2026

Effective Date:

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