I. GENERAL PROVISIONS

A. Principle

The protection of our customers’ privacy is very important to BestJet. We set out below the principles we follow and for which purpose we collect and process personal data (information that determines your identity or allows us to identify you; referred to hereinafter also as “data”) via this website, and other websites and applications (referred to hereinafter as the "website") operated by BestJet.

We collect and process your personal data carefully, only for the purposes described in this Privacy Statement and only to the extent necessary as defined therein and within the scope of the applicable legal regulations. We only store your personal data to the extent and as long as it is required for the performance of our services or as we are legally obliged to do so.

Under Section I you will find the general data protection information, under Section II, the provisions with regard to data processing in connection with carriage, and under Section III you will find further instances where data processing is used.

The terms of use for your BestJet profile and the General Conditions of Carriage for the operation of flights also apply.

B. Use of the website and cookies

We only request personal data where required for the performance of our own services and for the processing of transactions that you carry out with BestJet or our partners.

When you access our website, our system automatically records technical information about the computer accessing it. The data collected is information about the browser type and the version used, the operating system, the internet provider and the IP address of the user, the date and time of access, the websites from which the user’s system obtains access to our website, and the websites accessed by the user’s system via our website.

PeakJet uses so-called cookies to make it easier for you to use the BestJet website and other websites and applications operated by BestJet, and to obtain ideas for improving the information and services accessible via the website. Personal data is pseudonymised. You will find information about the use of cookies and analytical services on the BestJet website in our ​Cookie Policy.

The basis for this data processing is Art. 6(1)(a) and (f) GDPR.

C. Storage of customer data

For accounting reasons, BestJet generally stores the personal data collected from customers for processing bookings for 10 years after the last processing operation. We store other data as long as is necessary for the execution of the contract and to safeguard our rights. We reserve the right to apply longer statutory and operational storage requirements and reasons.

Personal data collected for marketing activities is generally deleted as soon as the purpose of the activity has been met.

The basis for this data processing is Art. 6(1)(f) GDPR.

D. Data security

We protect your personal data by means of appropriate technical and organisational security measures and store it solely on our secure servers. The website is secured against loss, destruction and manipulation by means of customary measures in accordance with the state of the art and against access, modification or distribution by unauthorised persons. Especially sensitive data (e.g. access data for your profile account) is encrypted during transmission via the internet (SSL).

However, BestJet does not assume any guarantee for the security of your data. It is your responsibility to make an up-to-date back-up of the transferred data at all times and store it separately from the website. You are also responsible for creating a secure password for your customer account, keeping it safe and changing it on a regular basis.

E. Rights of customers

You have the right to information, correction, erasure and portability of your data. You also have the right to restrict processing.

Paragraph C (Storage of customer data) and other statutory exceptions are reserved.

You have the right to object to the processing of your personal data. An objection only has future effect and does not affect previous processing. If, on account of the objection, BestJet is no longer able to perform the services contractually agreed with you, the objection is deemed to be a breach of contract by the customer and BestJet has the right to terminate its contract with you without notice. Payment obligations already contractually entered into by the customer remain in force.

To claim these rights, you can contact BestJet at the address given in paragraph F or use the ​data protection contact form.

If BestJet does not comply with the applicable data protection law, you have the right to file a complaint with the competent regulatory authority.

F. Contact

If you have any questions about this Privacy Statement or data protection at BestJet, please contact:

BestJet
PO Box
8058 Zurich Airport
Switzerland

info@BestJet.ch

We would like to point out that only inquiries relevant to data protection will be answered. 

G. Updates

We review our Privacy Statement regularly and update it as required. We will inform you of any important changes (e.g. on our website).

II. PROCESSING OF PERSONAL DATA IN CONNECTION WITH CARRIAGE

A. Purpose of data processing

PeakJet processes the personal data of its customers for the purpose of carriage, which includes in particular

• reservation,

• booking,

• rebooking,

• cancellation,

• managing check-in,

• communicating with the customer with regard to carriage,

• operating the flight,

• simplifying immigration procedures,

• processing irregularities in relation to baggage,

• improving offers from BestJet and its positioning in the market and

• securing payment transactions (also referred to hereinafter as “carriage”).

BestJet processes its customers’ personal data. This includes receiving personal data from third parties and the further processing of this data.

The basis for this data processing is Art. 6(1)(b) GDPR.

B. Sharing of data with the authorities in Switzerland and abroad

API data (“Advanced Passenger Information”) is basic information about passengers that is required by certain government authorities for entering and leaving the country. It includes the name, date of birth, sex, nationality, travel document data and e-mail address of passengers. API data also includes other data, such as flight information (e.g. flight number and arrival and departure times).

PNR data (“Passenger Name Record”) is all the information and data required for carriage (e.g. booking code, name, e-mail address, flight information, payment information and details of travelling companions), plus any additional data in connection with carriage, in particular information sent by you (e.g. frequent flyer information or special requests) or third parties (e.g. travel agencies).

For legal, security and regulatory reasons, we are obliged to transmit certain personal and booking data (including API and PNR data) to authorities in Switzerland and abroad.

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BestJet is also obliged to disclose your personal data to Swiss and foreign criminal prosecution, judicial or administrative authorities if they require the disclosure in order to prevent or prosecute crimes, misdemeanours or administrative misconduct or if they need it to fulfil their administrative duties.

For example, health authorities may receive passenger data for the purpose of combating a pandemic.

Data transfers to authorities are based on intergovernmental agreements or national laws. Usually, such data is required by the authorities of the country of departure and/or arrival.

The basis for this data processing is Art. 6(1)(f) GDPR.

C. Credit assessment and anti-fraud measures

We reserve the right to verify payment transactions in order to prevent fraud and other improper usage. To this end, we use both internal and external sources of information. For this purpose, we also use distinct, identifiable technical features. If fraudulent activity is suspected and/or detected, we also reserve the right to share the relevant information (including personal data) with other subsidiaries of the BestJet. which may also verify the data for their own purposes.

For use of the payment service purchase on account, see Section III paragraph I (Purchase on account).

The basis for this data processing is Art. 6(1)(f) GDPR.

D. Data processing by third parties in Switzerland and abroad

PeakJet allows personal data to be processed by third parties in Switzerland and/or abroad (also in countries where legislation does not guarantee appropriate data protection) for the purpose of operating the website and to meet the purposes stated in this Privacy Statement.

In the case of the transfer of data to countries without appropriate data protection, BestJet ensures that the measures required are implemented (generally by signing recognised data protection agreements, e.g. based on standard contractual clauses of the EU), in order to protect personal data in accordance with the applicable data protection law.

1. External data recipients

External recipients of personal data include

• service providers in the areas of ground handling, transport, marketing, customer feedback, IT, payment services and credit agencies,

• platforms for sending newsletters,

• healthcare service providers as part of combating the pandemic,

• operators of live help chat,

• companies of the BestJet.,

• airlines outside the BestJet.,

• partner companies as well as

• government agencies and authorities.

2. Combating fraud and “unruly passengers”

“Unruly passengers” are passengers who display improper, aggressive or violent behaviour towards other passengers or the crew, or who damage the aircraft.

PeakJet is entitled to exchange its passengers’ personal data within the operators of air services and with other airlines in order to document, analyse and prevent cases of fraud and instances of “unruly passengers”, and to process the data relating thereto.

If you have harmed or injured other passengers, BestJet can also disclose your personal data and information in connection with the harm and injury to other third parties (e.g. the authorities, injured persons and insurance companies).

The basis for this data processing is Art. 6(1)(f) GDPR.

3. Booking process

If you start a booking process, we collect booking data and personal data, in particular your surname, first name, date of birth, telephone number, e-mail address and, in encrypted form, your credit card details. This data is only stored if the customer initiates a payment process.

The basis for this data processing is Art. 6(1)(b) and (f) GDPR.

III. INSTANCES OF USE

A. BestJet.ch profile

1. Purpose of the BestJet.ch profile

You have the option of creating your own BestJet profile on the website. Your BestJet profile allows you to carry out flight bookings and use other booking services more easily, such as advance seat reservation, online check-in and in-flight services, and also to receive other offers from BestJet and our partner companies.

Personal data collected for the creation and operation of your profile

When you set up a BestJet profile, we ask for your personal data, in particular your surname, first name, date of birth, telephone number and e-mail address. However, only your e-mail address is compulsory. To set up your profile we use the so-called double opt-in procedure: After you have registered, we send you a notification e-mail. You can confirm the setup of your profile by clicking on a corresponding activation link.

In order to process flight bookings you have made that are operated by our partners, you can also store the following additional information in your profile: Your preferred payment method, your address and your PeakJet membership number. If you decide not to store certain additional information in your BestJet profile, you may be unable to access some specific functions or transactions.

PeakJet is entitled to process the data you share with us as part of your use of your BestJet profile, so that we can meet the resulting contractual obligations and operate your BestJet.ch profile.

3. Sharing of data with third parties; BestJet will collect and process within BestJet the data you share with us in your BestJet.ch profile and/or during your use of a function of the BestJet.ch profile and which is required for the use of your BestJet.ch profile (e.g. personal data, non-personal data and information), and may transfer data to partner companies as part for the purposes stated in this Privacy Statement. In addition, third-party companies commissioned by PeakJet for the technical management of the BestJet.ch profile may also obtain access to your data in the course of this activity.

4. Marketing activities and personalised advertising at PeakJet it is our ambition to offer you an air travel experience that is customised to you, your personal wishes and expectations from your first visit to our website and to the end of your trip and beyond.

a. Marketing and analytical activities for this purpose, BestJet processes your personal data collected in the course of registration and use of your BestJet.ch profile for marketing and analytical activities. As part of its marketing and analytical activities, BestJet may send you offers, for example about BestJet products and services which are similar to or the same as ones you have purchased or used previously. If you do not wish to receive such offers, you can delete your BestJet.ch profile at any time.

b. Personalised information and offers when you set up a BestJet.ch profile, we combine data about your consumption and usage patterns with BestJet and our partner companies and analyse it to provide you with relevant, personalised information and offers tailored to your interests (e.g. recommendations for specific flights or information on baggage conditions). By setting up your BestJet.ch profile, you agree that we may provide you with such information and offers. We will only collect, process and use additional personal data from other sources (e.g. from websites operated by third parties) to create personalised information provided that you have given such third parties consent to this effect.

c. Market research as part of our market research activities, BestJet may invite you to take part in surveys to improve our products and services.

d. Electronic communications by setting up a BestJet.ch profile, you give us your consent to send you relevant information, recommendations and offers from BestJet and our partner companies. This takes place by means of non-analogue communication, such as e-mail, telephone, SMS or instant messaging, for example. If you do not wish to receive such communications, you can delete your BestJet.ch profile at any time.

e. Flight-related surveys BestJet may invite you to take part in surveys in order to improve its services and as part of market research. These flight-related surveys will be sent electronically 3 days after the start of your flight. For this purpose, the explicit consent of the customer is obtained; e-mail address, flight route information and booking related data are collected.

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5. Deleting your BestJet.ch profile

You can delete your BestJet.ch profile at any time and without giving reasons. Your profile can then no longer be used and reactivated.

If you delete your BestJet.ch profile, BestJet will completely delete or anonymise the personal data contained in your profile. Statutory and operational storage requirements or reasons are reserved by BestJet.

The basis for this data processing is Art. 6(1)(a) GDPR.

B. Newsletters

On request, we will keep you informed about relevant developments and offers from BestJet. We use the so-called double opt-in procedure to subscribe to our newsletter: When you subscribe to our newsletter on the website, for example by clicking a confirmation field, we will send you a notification e-mail. You can confirm your subscription by activating the relevant link. If you no longer wish to receive newsletters from BestJet, you can either unsubscribe free of charge in the newsletter itself or in your BestJet.ch profile, at any time. Doing so will not restrict the use of your BestJet.ch profile.

We process your data associated with the newsletter in order to send you news about and related to BestJet and our partners. In addition, we also process and use the e-mail address you have entered in order to send you personalised offers associated with the newsletter.

If a link in the newsletter directs you to our websites, you also give us permission to process and use your IP address, together with geodata, web beacons or similar technologies, in order to verify whether the offers presented to you in the course of this communication meet your requirements.

BestJet works together with external service providers for sending out the newsletter.

The basis for this data processing is Art. 6(1)(a) GDPR

C. Customer satisfaction surveys

In the course of analytical activities and in order to offer you a better customer experience, BestJet may ask you to take part in customer satisfaction surveys after you have completed your BestJet flight. If at a later date you no longer wish to receive such offers or requests, you can unsubscribe from these free of charge at any time via the link provided in the corresponding e-mail.

The basis for this data processing is Art. 6(1)(f) GDPR.

D. Chat assistant

You can use the BestJet chat assistant to contact us and communicate with us on our website BestJet.ch.

We recommend you to be cautious about disclosing personal data and only share information in the chat that is necessary for the service you would like to use.

You can also contact us via the messenger service (referred to below as “Facebook Messenger”) provided by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (referred to below as “Facebook”). Facebook may process your data in the USA.
Please be informed that, according to the European Court of Justice, there is no adequate level of protection for the transfer and processing of personal data in the USA.
Please also note that Facebook does not provide an end-to-end encryption for communication via Facebook Messenger and we are unable to provide encryption through additional technical measures.

We also cannot prevent Facebook from reading data that you reveal in the course of the chat, combine them other data and that this may be used for example for advertising tailored to your interests, or shared with third parties.

You will find further information about the processing of your personal data at Facebook in the Facebook privacy policy.

To the Facebook privacy policy

You can contact the Data Protection Officer of Facebook via the online contact form provided by Facebook.

To the Facebook contact form

In the situation described above, we will therefore ask for your consent that Facebook may receive your data before your first contact via Facebook Messenger.

You can withdraw your consent with future effect at any time. To do so, please enter the word “Withdraw” in the Facebook Messenger dialogue window and confirm the withdrawal option offered to you, or follow the menu link “Data Protection” in the dialogue window.

Which functions can you use and for which purposes do we process your data?

a) Chat function

If you contact the chat assistant via a webchat, a session-based pseudonymised User ID will be assigned to you. The content of your inputs and the answers from the chat assistant will be stored with this User ID.

All data you enter in the webchat dialogue with the chat assistant in the course of the chat are passed to a commissioned data processor and processed there for the purpose of handling your enquiries. Your chat entries will be analysed to handle your concern and compared with the functionalities and information provided by us to our data processor. If it is not possible to handle your enquiries in this process step via a dialogue provided in the software, your input texts will be shared with another commissioned data processor, who analyses them using special software and compares them with a knowledge database, whose content is also provided by us. Entries matching your input text will be sent back to you.

If you send us an enquiry via Facebook Messenger, you will be assigned a session-based, pseudonymised User ID by Facebook. This will be transferred to us including your Facebook username. This will allow us to identify you again in the event of later enquiries via Facebook Messenger and place your enquiry in context with previous conversations with you. Facebook additionally transfers your language and gender, which allows us to address you in a personalised form.
No further data and information about you stored on Facebook will be transmitted.

The legal basis for processing your data is:

• Art. 6(1)(1)(b) GDPR if your concern relates to an existing or planned booking

• Art. 6(1)(1)(f) GDPR to safeguard our legitimate interest in the establishment, exercise and defence of legal claims.

b) Live chat function

If the chat assistant is unable to process your questions or enquiries, the live chat function of the chat assistant gives you the option of contacting our Service Centre. If you use this live chat function, the personal data you entered in the course of the chat is transferred to our commissioned data processors which will reply to you via the chat assistant on our website.

The legal basis for processing your data is:

• Art. 6(1)(1)(b) GDPR if your concern relates to an existing or planned booking

• Art. 6(1)(1)(f) GDPR to safeguard our legitimate interest in the prevention of fraud and for the establishment, exercise and defence of legal claims.

 c) Feedback function

You can also send us your feedback about the information provided by the chat assistant by using the “Thumbs up” and “Thumbs down” function. Your feedback will be stored combined with the progress of your webchat. If you wish to give feedback about the chat assistant, you have to request this explicitly by text input. You then have the option of entering your feedback in text form in the webchat.

The legal basis for processing your data is Art. 6(1)(1)(f) GDPR to protect our legitimate interest in improving the functions of the chat assistant based on your feedback.

d) Push notifications
If you contacted us via Facebook Messenger and gave us your consent there, we will send you information about your booking, for example that your flight is ready for check-in, providing you gave us your booking data via Facebook Messenger.

You can withdraw your consent with future effect at any time. To do so, please enter the word “Withdraw” in the Facebook Messenger dialogue window and confirm the withdrawal option offered to you, or follow the menu link “Data Protection” in the dialogue window.

The legal basis for processing your data is Art. 6(1)(1)(a) GDPR.

e) Quality improvement

We analyse all dialogues and your feedback to improve the functionalities of the chat assistant. To do so, all references to you are removed, so that only anonymised data is used for this purpose and your data cannot be analysed or linked with you.

Who are the recipients of your data?

We share your personal data with other affiliated companies within the BestJet. or external companies to process your enquiry via the chat assistant.

We reserve the right to disclose information about you if required by law, or if we are asked to do so by authorised authorities or the courts.

CompanyActivity

Microsoft Ireland Operations Limited
Atrium Building Block B
Carmenhall Road
Sandyford Industrial Estate
Dublin 18
Ireland Commissioned data processing.
Information database: If your enquiry cannot be answered satisfactorily, the text you have entered is forwarded to the data processing company Microsoft. These input texts will be subject to speech analysis there and compared with a knowledge database. Entries matching your entered text will be sent back to you. Microsoft only receives the text you entered during the chat with the chat assistant (including all personal data you disclosed within this context). Language translation in the live chat:
We use Microsoft translation software to connect you more quickly with an agent in the live chat, which allows the translation of your chat inputs into the relevant language of the agent and vice versa.  

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When is your data deleted?

We delete your data transmitted via the chat assistant after 30 days. The 30-day retention period for the chat assistant function does not affect the retention period for personal data processed for the fulfilment of the contract of carriage. Please refer to our General Conditions of Carriage and the relevant details in our data protection information.

E. Facebook

1. BestJet Facebook page

Attractive offers on flights are communicated on the official BestJet Facebook page along with company and product updates.

The BestJet Facebook page offers round the clock customer service: answering customers’ questions, and supporting them with re-bookings and irregularities.

In keeping with our legitimate interests, we process data for the following purposes:

• Evaluation of statistical analysis in relation to users’ interactions on the Facebook page;

• Optimisation of the Facebook page with regards to attractiveness and ease of use, and the implementation of marketing measures to support user needs;

• Other communication and interactions initiated by Facebook users.

2. Chatbot

PeakJet offers online advice in the form of automated chat (chatbot) on some of its Facebook pages. BestJet is working together with external service providers for the operation of the live chat service. During a chat, information from your Facebook profile (e.g. name, language) as well as your respective input will be processed in the Facebook Messenger Chat. If the chatbot cannot process your request itself, the chat will then be handed over to a member of our customer service team at your request. These members of our customer service team can view the past chat history and see your Facebook profile name.

You can find detailed information about the ​processing of your data when you use the chatbot service here.

The basis for this data processing is Art. 6(1)(f) GDPR.

F. Offers from third parties as part of carriage

In the scope of the carriage, BestJet will show you offers from third parties (e.g. from hotels or car rental companies) on its website; these offers are created on an anonymous basis. If you have given us your consent to this effect, we will also show you such offers as part of the communication before your departure.

The basis for this data processing is Art. 6(1)(a) GDPR.

G. Insurance

PeakJet offers you travel insurance provided by a third party on its website at the time of booking. If you take out the insurance (i.e. if it is "ordered" online), BestJet receives data from you, performs the billing directly on behalf of the third party (payment is made to BestJet) and sends data to the third party, such as the name of the person applying, the length of the trip and the booking code.

The basis for this data processing is Art. 6(1)(b) GDPR.

H. Purchase on account

In order to use the “purchase on account” payment service, BestJet processes your personal data (e.g. first name and surname, address, date of birth, e-mail address and mobile telephone number, as well as information on the outstanding amount, the currency used and the booking data), and the usage data of your website visits to BestJet (e.g. information about the start, end and scope of the websites you visited, your IP address and click paths). The basis for processing is created by cookies and/or a visitor ID, which may include anonymous data regarding the end devices you used when visiting the websites (e.g. your screen resolution or the version of your operating system). BestJet can transfer such data to third-party companies engaged to provide the “purchase on account” payment service and have this data processed by such companies.

If you select the “purchase on account” payment service, your data is used and processed for the purpose of providing this payment service, for identity and creditworthiness checks (this may also include obtaining references from other third parties, such as credit agencies) and for risk management (including fraud and abuse prevention and also with the involvement of further third-party companies). If there is any suspicion of fraud, BestJet will verify the assessment and the underlying evidence. You will be BestJet if your application has been declined.

You may cancel this agreement with BestJet informally with future effect and at any time. Any further use of the “purchase on account” payment service will then no longer be possible. The identity, creditworthiness and fraud checks carried out for the “purchase on account” payment service are governed solely by the provisions of the respective third-party company.

The basis for this data processing is Art. 6(1)(b) and (f) GDPR.

I. The PeakJet app

With the BestJet app, BestJet provides you with the option of searching for flight information, booking flights, loading your flight bookings into the app, carrying out check-in procedures and displaying boarding passes and temporarily storing them. In order to obtain information on a flight booking, you must enter your booking code or the flight number, or log in using your BestJet.ch profile. Once you have logged in, you receive a summary and further information about bookings linked to your profile. This data is stored temporarily in the app in protected form and is deleted as soon as it is no longer visible in your BestJet.ch profile. The login data is transferred to BestJet by the app to identify the user.

The basis for this data processing is Art. 6(1)(b) GDPR.

 Google Analytics

Google Play Services

Firebase Analytics

Fabric

 Crashlytics

Distil

Tealium

J. Sponsorship and cooperation requests

For the purpose of verifying and processing requests related to a potential sponsorship/partnership relationship, BestJet processes the personal data of the applicants.

The basis for this data processing is Art. 6(1)(b) GDPR.

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