Privacy Policy

Effective date: 01/01/2022
Last revised date: 01/11/2021

A cookie is a small file stored by a server in the terminal (computer, telephone, etc.) of a user and associated with a web domain (i.e. in most cases with all the pages of the same website).  This file is automatically returned on subsequent contacts with the same domain.”[1]

Improvement purposes

BIRDY processes the Personal Data of its Clients in order to provide them with an adapted and personalized service, in this case to ensure the most comfortable flight service possible and to provide other travel-related arrangements.

To this end, BIRDY uses Personal Data to, among other things:

  • Process general questions asked by the Clients;
  • Obtain feedback on its services and the services of third party suppliers, in order to improve and develop them;
  • Deliver relevant messages and information that may be of interest to Clients before, during and after their trip;
  • Personalize and tailor the travel experience;
  • Participate in the training of its employees and thus participate in the improvement of its products and services;
  • Geographically tracking Clients within airports (e.g., tracking security checkpoints) to facilitate flight connections and fast and efficient boarding of aircraft, as well as to provide personalized service; and
  • Use facial recognition and related biometric technologies to facilitate passenger boarding.


Legal and Regulatory Obligations

BIRDY is subject to a number of legal and regulatory obligations under which Personal Information must be disclosed.

Indeed, BIRDY may be required to transmit and communicate the Personal Data collected (including data obtained from official photo identification documents) to competent authorities such as passport and border control agencies and competent police and customs authorities. BIRDY may also disclose Personal Data to make travel arrangements such as airport and immigration formalities.

It is understood that this communication is a legal obligation of BIRDY, which cannot avoid it, just as the Client cannot object to it.


Security Purposes

BIRDY will also use Personal Data to perform the following checks:

  • BIRDY will ensure that the Client or any Passenger is not the subject or target of any economic or trade sanction law or regulation or travel ban by conducting due diligence on the Client’s background (sanctions and execution list data) to protect the rights, interests, property and safety of the Client and Clients;
  • For general administration of records by BIRDY, which may include, for example, accounting and billing, auditing, credit or other payment card verification, fraud screening (including the use of credit reference agency searches and payment card validation checks), immigration and customs control, safety, security, health, administrative and legal purposes, and systems testing, maintenance and development; and
  • To fulfill obligations and/or enforce rights under any contract between BIRDY and Client.


Further processing

In the event that Personal Data is further processed for purposes other than those for which the Personal Data was collected and as identified above, BIRDY will provide the Data Subject with prior information about such other purpose and any other relevant legal information required.

BIRDY may disclose Personal Data to the following entities:

  • Aircraft operators, aircraft owners, private jet companies and airlines in general;
  • The operating carrier (if BIRDY arranges for transportation by another carrier, that other carrier is the operating carrier as defined in the legislation governing air transportation);
  • Third parties involved in the performance of BIRDY’s obligations in connection with any contact with the Client; and
  • Authorized representatives (such as, but not limited to, employees, agents, mandatories) of BIRDY.


Third parties may also have access to Personal Data in the following cases:

  • In the event of a legal or regulatory obligation to disclose Personal Data (US, European or otherwise)
  • As part of contractual obligations between BIRDY and/or the Client and/or an Operator;
  • In the event that BIRDY sells its entire business or assets, disclosure will be made only to the purchaser and its professional advisors;
  • In the case of a due diligence exercise conducted on BIRDY by a potential investor or partner, disclosure will be made to the potential investor or partner and its professional advisors and will be subject to confidentiality protections to the extent possible;
  • For security purposes to conduct due diligence or other background checks on the Client (sanctions and execution list data);
  • For the protection of the rights, property and safety of BIRDY and its Clients (including by exchanging information with third parties for fraud protection and credit risk reduction purposes); and
  • To facilitate travel arrangements, including other carriers and airport operators, customs and immigration authorities, agents or other brokers involved in travel arrangements, and global distribution system service providers that provide services to the Client or BIRDY, such as companies that provide airport handling, ground handling, catering, fuel, transportation, and flight personnel (pilots and cabin crew).


A number of legal and regulatory obligations are imposed to BIRDY whom is required to disclose Personal Data, such as official photo ID cards, to competent authorities, such as passport and border control authorities and competent police and customs authorities. BIRDY may also disclose Personal Data for travel arrangements such as airport and immigration procedures.

It is understood that this communication is a legal obligation of BIRDY, which cannot be avoided, just as the Client cannot object to it.

The Client is informed that BIRDY may transfer its Personal Data to a third country or to an international organization that is the subject of an adequacy decision issued by the European Commission, it being specified that, in the case of a transfer to a country or an international organization that is not the subject of an adequacy decision, this may only be carried out on condition that appropriate guarantees are put in place and that the Clients concerned have enforceable rights and effective means of recourse, under the conditions of the Regulations in force.


BIRDY guarantees that it has taken all reasonable and necessary measures to secure the Personal Data of its Clients, in accordance with this Policy and with the obligations imposed by the RGPD and by any applicable Data protection-related regulations. To this end, a set of physical, electronic and management procedures have been put in place.

As such, a contractual obligation of confidentiality regarding Personal Data may be applied to all BIRDY employees who may have access to or be associated with the processing of such Personal Data; they may not disclose the identity of Clients, either orally or in writing, or even take or publish a photo of Clients (except for legal and regulatory obligations) without their explicit prior consent.

BIRDY shall however not be liable should any supplier disrespect these confidentiality principles within the frame of their own Terms & Conditions.



Personal Data will be stored and processed by BIRDY’s systems and may also be stored and processed by the systems of one or more designated third party data processors.



Personal Data collected by BIRDY may be transferred to a destination outside the European Economic Area (“EEA“) and stored there. It may also be processed by employees operating outside the EEA who work for BIRDY or one of its suppliers.

By submitting their Personal Data through access, use and purchase of services from BIRDY, Clients agree to such transfer, storage or processing.

BIRDY informs Clients that its website may contain links to and from the websites of its network of partners and affiliates.

The links lead to websites that are independent from BIRDY and that contain their own privacy policy and their own measures to secure Personal Data. The Client acknowledges that it is solely responsible for the confidentiality of its Data if it chooses to follow these links. BIRDY does not undertake any responsibility for the privacy policies of these third party websites.

The Client is strongly advised to consult the privacy policies of these websites before submitting Personal Data or using their services.