VICUNA AIR LIMITED

1. Who We Are (The Controller)

We are Vicuna Air Ltd (“Vicuna Air,” “we,” “us,” or “our”), a pet-inclusive air travel 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 information of our customers and website visitors, together with information linked to the pets travelling with us.

Unless notified otherwise, we are the data controller of your personal information.

2. Information We Collect

We collect information to help keep our services safe, process bookings and payments, and deliver our “Fly Gently” experience.

3. How We Use Your Information

We only use personal information when the law allows us to do so. The table below explains the main purposes for which we use it and the lawful basis we rely on.

4. Marketing Communications

4.1 Marketing Emails

When you provide your email address through one of our forms – for example when registering interest in a route, requesting a callback, subscribing to updates, or completing a booking – we may use it to send you marketing communications about Vicuna Air, including new routes, flight schedules, offers, and news.

We will only send you marketing where we are permitted to do so, either because you have consented or because we have a legitimate interest in keeping existing customers informed about similar services.

4.2 Photography, Publicity and Customer Stories

From time to time, we may invite passengers to participate in promotional photographs or customer stories. Where identifiable passenger information, including linked pet information, is used, we will obtain appropriate consent. Participation is optional and will not affect your booking or travel.

5. Cookies and Similar Technologies

We use cookies and similar technologies on our website for functionality, security, analytics and, where applicable, advertising purposes. For further information about the technologies we use, their purposes and how you can manage your preferences, please see our Cookie Policy.

6. Sharing Your Information

To operate our flights and provide our services, we may share limited personal information with trusted third-party partners and, where appropriate, with other passengers travelling on the same flight. We limit what we share to what is reasonably necessary for the relevant purpose and require our third-party partners to protect it appropriately.

• 6.1 The Operator: We share passenger and pet manifests with Talon Air (or the specific Direct Air Carrier) for flight safety and security clearance.
• 6.2 Financial Protection: We share necessary booking information with Avitrust in connection with the escrow, depository or other financial-protection arrangements applicable to your booking.
• 6.3 Payment Processing: Transactions are processed securely by Shift4.
• 6.4 Government and Regulatory Bodies: We are legally required to share manifest and other information with applicable aviation, customs, immigration, border and regulatory authorities in the jurisdictions we operate to, from, or through (for example, the US Department of Transportation, the UK Civil Aviation Authority, US Customs and Border Protection, and UK Border Force).
• 6.5 Veterinary and Handling: In Biscuit Class, relevant medical information may be shared with emergency vets or our professional handlers if a health issue arises mid-transit.
• 6.6 Messaging (WhatsApp): If you contact us via WhatsApp, your messages are handled by WhatsApp/Meta under their own terms and privacy policy. We may use automated assistance to respond to initial enquiries, with our team taking over where needed.
• 6.7 Fellow Passengers: We may share limited information with other passengers travelling on the same flight, including your first name, your pet’s name and photograph, and your seat allocation, where reasonably necessary for seating plans, boarding, cabin coordination, and the operation of the flight.

7. International Transfers

Because we operate internationally, your personal information may be transferred outside the UK/EEA.

8. Data Retention

We will only retain your personal information for as long as necessary for the purposes for which we collected it, including to meet legal, accounting and reporting requirements.

• Financial and Accounting Records: Retained for the period required by applicable tax, accounting, and legal requirements.
• Booking and Transaction Records: Retained for as long as reasonably necessary for contractual, legal, regulatory, and claims purposes.
• Identity and Travel Documents: Passport, ID, and similar documents are retained only for as long as operationally or legally necessary.
• Pet Health and Transport Records: Retained only for as long as necessary for travel, safety, regulatory requirements, or other necessary record-keeping.
• Marketing Information: Retained until you opt out or unsubscribe, subject to retaining limited suppression records where necessary to ensure your preferences are respected.

9. 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 personal information we hold about you.
• Right to Rectification: Correct incomplete or inaccurate personal information.
• Right to Erasure: Ask us to delete your personal information (the “Right to be Forgotten”) where there is no good reason for us continuing to process it.
• Right to Restrict Processing: Ask us to restrict the use of your personal information in certain circumstances.
• Right to Data Portability: Where applicable, ask us to provide certain personal information in a structured, commonly used and machine-readable format.
• Right to Withdraw Consent: Where we rely on your consent, you may withdraw it at any time without affecting processing carried out before withdrawal.
• Right to Complain: You may lodge a complaint with the UK Information Commissioner’s Office (ICO) or, where applicable, your local EEA data protection authority.

9.1 Your Right to Object

Where we rely on legitimate interests to process your personal information, you have the right to object to that processing. You also have an absolute right to object to the use of your personal information for direct marketing.

To exercise your rights with Vicuna Air, please email us at fly@vicunaair.com

10. Questions and Complaints

If you have any concerns about how we collect or use your personal information, or wish to make a data protection complaint, please contact us at fly@vicunaair.com.

We will acknowledge your complaint within 30 days and, without undue delay, take appropriate steps to investigate your concerns, keep you informed where appropriate, and notify you of the outcome.

You also have the right to make a complaint to the UK Information Commissioner’s Office (ICO).

11. United States Privacy Rights

Where a US state privacy law applies to our processing of your personal information, you may have additional rights under that law.

12. Children’s Privacy

Vicuna Air does not accept bookings from anyone under the age of 18. Children aged 10 or over may travel with a parent or guardian.

Where a child travels with us, we may process their personal information where necessary to arrange and provide their travel, comply with legal or regulatory requirements, and protect their safety. This information will be provided by, or with the involvement of, their parent or guardian.