VICUNA AIR PRIVACY POLICY

Effective Date: 15/12/2025

1. Who We Are (The Controller)

We are Vicuna Air Ltd ("Vicuna Air," "we," "us," or "our"). We are a humane air transport company registered in England and Wales.

We respect your privacy as much as we respect your pets. This policy explains how we collect, use, and protect the personal data of "The Pack" – our customers, their pets, and visitors to our website.

Registered Office:

Vicuna Air Limited
Hangar 4,
West Raynham Airfield,
Fakenham,
NR21 7PL,
United Kingdom

Contact: jamie@vicunaair.com

Unless notified otherwise, we are the Data Controller of your personal information.

2. Information We Collect

We collect data to ensure safety, process payments, and deliver our "Fly Gently" experience.

A. Information You Give Us

  • Identity Data: Name, date of birth, passport details (for you and authorised receivers).
  • Contact Data: Billing address, email address, telephone numbers.
  • Pet Data: Name, breed, weight, age, microchip number, vaccination records, and behavioural notes. While pet data is not strictly "Personal Data" under GDPR, we treat it with the same high security.
  • Biscuit Class Data: If using our unaccompanied service, we collect ID details of the "Authorised Receiver" at the destination.
  • Financial Data: Bank account and payment card details (processed via Shift4).

B. Information We Collect Automatically

  • Technical Data: IP address, browser type, and device identifiers when you use our website.
  • Usage Data: How you navigate our site and view our flight schedules.

3. How We Use Your Data

We will only use your data when the law allows. Most commonly, we use it in the following circumstances:

PurposeType of DataLawful Basis
To Register YouIdentity, ContactPerformance of a Contract
To Process Your Booking (Including Escrow & Payment)Identity, Financial, TransactionPerformance of a Contract
To Ensure Safety (Flight Manifests)Identity, Passport, Pet Health DataLegal Obligation (Aviation Regulations)
Biscuit Class Management (Handover & Vet Authority)Identity (Receiver), Pet MedicalPerformance of a Contract; Vital Interests
Marketing ("Join the Pack" updates)Contact, UsageConsent or Legitimate Interest
To Comply with DOT/UK CAAIdentity, TravelLegal Obligation

4. Sharing Your Data (The Extended Pack)

To operate our flights, we must share specific data with trusted third-party partners. We require all third parties to respect the security of your data.

  • The Operator: We share passenger and pet manifests with Talon Air (or the specific Direct Air Carrier) for flight safety and security clearance.
  • Financial Protection: Your funds are held in escrow. We share necessary booking data with Avitrust to secure your funds until the flight departs.
  • Payment Processing: Transactions are processed securely by Shift4.
  • Government Bodies: We are legally required to provide manifest data to Customs and Border Protection (CBP) in the US, and Border Force in the UK.
  • Veterinary & Handling: In Biscuit Class, medical data may be shared with emergency vets or our professional handlers if a health issue arises mid-transit.

5. International Transfers

Because we are a UK company flying to the US, your data will be transferred outside the UK/EEA.

The Safeguard:

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the UK Government or European Commission (Standard Contractual Clauses or IDTA).

6. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • Booking Data: Retained for at least 7 years for tax and legal liability purposes.
  • Marketing Data: Retained until you opt-out or unsubscribe.

7. Your Rights (UK & GDPR)

If you are a resident of the UK or EEA, you have rights under data protection laws, including:

  • Right to Access: Request a copy of the data we hold about you.
  • Right to Rectification: Correct incomplete or inaccurate data.
  • Right to Erasure: Ask us to delete your data (the "Right to be Forgotten") where there is no good reason for us continuing to process it.
  • Right to Object: Object to processing where we are relying on a legitimate interest.

To exercise these rights, please email us at support@vicunaair.com

8. United States Privacy Addendum

If you are a resident of the United States, specifically California, Virginia, or Colorado, this section applies to you in addition to the above.

8.1. California Residents (CCPA/CPRA)

  • Right to Know: You may request the specific pieces of personal information we have collected about you in the past 12 months.
  • Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions (such as DOT record-keeping requirements).
  • Do Not Sell/Share: Vicuna Air does not sell your personal data to data brokers. We do share data with our operational partners (Talon Air, Avitrust) solely to provide the service you requested.
  • Sensitive Personal Information: We collect sensitive information (Passport/ID) only for the purpose of providing air transport services.

8.2. Exercising US Rights

To exercise your rights under US State laws, please contact us at support@vicunaair.com. We will verify your identity before processing the request to protect the Pack.

9. Children's Privacy

Vicuna Air does not knowingly collect data from children under 13 without parental consent. If a child travels, their data is provided solely by the parent or guardian as part of the booking process.

10. Updates to This Policy

We may update this policy as "The Pack" grows or regulations change. The latest version will always be posted on this page.

Last Updated: 15/12/2025