1. Introduction
Diaolancq Ltd. ("we", "our", or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose and safeguard your information when you visit our website diaolancq.com (the "Site") and use our private aviation services.
We are bound by the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws in Canada. By using our Site and services, you consent to the practices described in this policy.
2. Information We Collect
2.1 Personal Information
We may collect personal information that identifies you as an individual, including but not limited to:
- Identity Information: First name, last name, title, date of birth
- Contact Information: Billing address, delivery address, email address, telephone numbers
- Financial Information: Payment card details, billing information (processed securely through third-party payment processors)
- Travel Information: Passport details, special dietary requirements, accessibility needs, passenger preferences
- Profile Information: Username, password, purchases or orders, interests, preferences, feedback and survey responses
2.2 Automatically Collected Information
When you visit our Site, we may automatically collect certain information about your device and browsing activities:
- Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform
- Usage Data: Information about how you use our Site, products and services, including page views, traffic patterns, search queries and click-stream data
- Device Information: Device type, unique device identifiers, mobile network information
2.3 Cookies and Similar Technologies
We use cookies and similar tracking technologies to collect information about your browsing activities. Please refer to our Cookie Policy for detailed information.
3. How We Use Your Information
We use your personal information for the following purposes:
- Service Delivery: To provide, operate and maintain our private aviation services, including flight bookings, route planning and in-flight services
- Communication: To send you administrative information, updates, security alerts and support messages
- Customer Support: To respond to your inquiries, comments and requests
- Personalization: To tailor your experience and deliver content and product offerings relevant to your interests
- Marketing: To send promotional communications about our services, special offers and events (with your consent, where required by law)
- Legal Compliance: To comply with applicable laws, regulations, legal processes or governmental requests
- Security: To protect the rights, property and safety of Diaolancq, our clients, employees and the public
- Business Operations: For data analysis, audits, fraud monitoring and prevention, developing new products, enhancing our website and identifying usage trends
4. Legal Basis for Processing (PIPEDA Compliance)
Under PIPEDA, we collect, use and disclose your personal information only with your knowledge and consent, except where required or permitted by law. Our legal bases for processing include:
- Consent: You have given explicit consent for one or more specific purposes
- Contract Performance: Processing is necessary for the performance of a contract with you
- Legal Obligations: Processing is necessary for compliance with a legal obligation
- Vital Interests: Processing is necessary to protect your vital interests or those of another person
- Legitimate Interests: Processing is necessary for our legitimate interests, provided your rights and freedoms do not override those interests
5. How We Share Your Information
We may share your personal information in the following circumstances:
- Aviation Partners: With certified air operators and aviation service providers who perform flights and related services on our behalf
- Service Providers: With third-party vendors who provide services such as payment processing, data analysis, email delivery, hosting services and customer service
- Legal Requirements: When required by law, subpoena, court order or other legal process
- Business Transfers: In connection with a merger, sale of company assets, financing or acquisition of all or a portion of our business
- With Your Consent: We may disclose your personal information for any other purpose with your explicit consent
We do not sell, trade or rent your personal information to third parties for their marketing purposes.
6. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements, to resolve disputes and to enforce our legal agreements and policies.
Specific retention periods:
- Booking Information: 7 years from the date of service (as required by Canadian aviation and tax regulations)
- Marketing Communications: Until you withdraw consent or unsubscribe
- Website Analytics: 26 months from collection
- Financial Records: 7 years from transaction date
7. Data Security
We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure or destruction, including:
- Encryption of sensitive data in transit and at rest
- Regular security assessments and vulnerability testing
- Restricted access to personal information on a need-to-know basis
- Secure payment processing through PCI-DSS compliant providers
- Employee training on data protection and privacy
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.
8. Your Privacy Rights
Under PIPEDA and applicable Canadian privacy laws, you have the following rights:
- Access: Request access to your personal information and receive a copy of the data we hold about you
- Correction: Request correction of inaccurate or incomplete personal information
- Deletion: Request deletion of your personal information, subject to legal retention requirements
- Withdrawal of Consent: Withdraw consent for processing at any time (note: this may affect our ability to provide services)
- Data Portability: Request transfer of your data to another organization in a structured, machine-readable format
- Opt-Out: Opt-out of marketing communications at any time
- Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada if you believe your rights have been violated
To exercise these rights, please contact us at [email protected] or write to:
Privacy Officer
Diaolancq Ltd.
110 Bloor St W
Toronto, ON M5S 2W7
Canada
We will respond to all requests within 30 days, as required by law.
9. International Data Transfers
Your personal information may be transferred to and processed in countries other than Canada. When we transfer your information internationally, we ensure appropriate safeguards are in place, including:
- Standard contractual clauses approved by relevant authorities
- Data processing agreements with recipients
- Ensuring adequate levels of data protection in recipient countries
10. Children's Privacy
Our services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information.
For minors aged 13-17, we require parental or guardian consent before collecting personal information.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. We will notify you of any material changes by:
- Posting the new Privacy Policy on our Site
- Updating the "Last Updated" date
- Sending email notification (for significant changes)
Your continued use of our Site and services after such changes constitutes your acceptance of the new Privacy Policy.
12. Contact Information
If you have any questions, concerns or requests regarding this Privacy Policy or our data practices, please contact us:
Email: [email protected]
Phone: +1 416-461-1823
Office Address:
110 Bloor St W
Toronto, ON M5S 2W7
Canada
Office Hours: Monday–Friday 08:00–20:00, Saturday 10:00–16:00 (Eastern Time)
