PRIVACY AND COOKIE POLICY

SoHo Jets LLC (“SoHo Jets,” “we,” “us,” or “our”) is committed to safeguarding the privacy of a given user (“user,” “you,” or “your”). This Privacy and Cookie Policy (this “Policy”) describes our policies and procedures regarding the collection, use, and disclosure of information we obtain through the SoHo Jets website (http://www.flysohojets.com) (the “Site”) or by providing flight booking or chartering services in conjunction with the Site (collectively, the “Services” or the “SoHo Jets Platform”). Please read the following information carefully to understand our views and practices regarding your personal data and how we treat it.

1. Particularly Important Information.

WHO WE ARE. For the purpose of applicable data protection legislation, the data controller of your personal data is SoHo Jets, an Arizona limited liability company.

MUST-READ SECTIONS. We draw your attention in particular to the sections titled “INTERNATIONAL DATA TRANSFER” and “YOUR RIGHTS” below.

CHANGES TO THIS POLICY. We will post any modifications or changes to this Policy on the Site. We reserve the right to modify this Policy at any time, so we encourage you to review it frequently. The “Last revised” legend above indicates when this Policy was last changed. If we make any material change to this Policy, we will notify you via email or post a notice on our Site prior to such change taking effect.

2. Legal Bases for Processing EU Personal Data.

We use your personal information only as permitted by law. Our legal bases for processing the personal data described in this Policy are as follows:

a. Legal Compliance. We may need to collect, use, and otherwise process your personal data to comply with our legal obligations, such as regulatory monitoring and reporting obligations.

b. Legitimate Interests. We may process your personal data where we have a legitimate interest in doing so, provided that our interests are not outweighed by any potential impact of the processing on you or your fundamental rights and freedoms.

c. Contract. We may need to process your personal data to perform a contract with you or to take steps that you have requested prior to entering into the contract.

d. Necessity. We may need to process your personal data to protect your vital interests or those of another person.

e. Consent. In some cases, we may rely on your consent to process your personal data. Where we rely on your consent, you have the right to withdraw it at any time in the manner indicated when we requested the consent or by contacting us as described in this Policy.

3. How We Collect Your Information.

a. Information You Provide.

i. We collect personal data from users when they register to use the SoHo Jets Platform, post content on the SoHo Jets Platform, or communicate with us (e.g., through the [“Contact us”] page on the Site or when requesting customer service or technical support), make reservations or purchases through the SoHo Jets Platform, or provide us with feedback about the SoHo Jets Platform. We may also collect personal data at other points in the SoHo Jets Platform when clearly identified.

ii. To create an account, users may provide optional information such as a profile photo, location, job title, and email address. Users may always go to the [“My account”] section of the SoHo Jets Platform to update, change, or remove such information.

b. Information Collected via Technology.

i. Information Collected by Our Servers. To make the SoHo Jets Platform more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, which may include your browser type, operating system, internet protocol (“IP”) address (a number that is automatically assigned to your computer when you use the internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

ii. Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser types, internet service providers (“ISP”), referring/exit pages, operating systems, date/time stamps, data typed into the Site, and clickstream data. We use this information to analyze trends, administer the SoHo Jets Platform, track users’ movements around the SoHo Jets Platform, gather demographic information about our user base as a whole, and better tailor the SoHo Jets Platform to our users’ needs. For example, certain information may be collected so that, when you visit the SoHo Jets Platform again, it will recognize you and remember your preferences. Except as noted in this Policy, we do not link this automatically collected data to personal data.

iii. [How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable you to opt out of tracking on the Site. To find out more about “do not track,” please visit http://www.allaboutdnt.com.]

iv. [Analytics Services. In addition to the tracking technologies we place, other companies may set their own Cookies or similar tools when you use the SoHo Jets Platform. This includes third-party analytics services, such as Google Analytics (“Analytics Services”), that we engage to help analyze how users use the SoHo Jets Platform, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve the SoHo Jets Platform. The information generated by the Cookies or other technologies about your use of the service (the “Analytics Information”) is transmitted to the Analytics Services

The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties when required to do so by law, or when such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using the SoHo Jets Platform, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set forth above. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you do not want to take advantage of these services, you can opt out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/, or, if you are located in the EU, http://www.youronlinechoices.eu/.]

v. [SNS Login. Users may use certain social media site (“SNS”) credentials to log into the SoHo Jets Platform. In such case, we collect personal data from the social media website. For example, when you log in with your Google credentials, we may collect the personal data you have made publicly available in Google, such as your email address, name, and profile picture or logo. You agree that you are solely responsible for your use of an SNS and that it is your responsibility to review the terms of use and privacy policy of such SNS. Any information that we collect from an SNS account will depend on the privacy settings you have with that SNS, so please consult the SNS’ privacy and data practices. We will not be responsible or liable for (i) the availability or accuracy of such SNS, (ii) the content, products, or services on or availability of such SNS, or (iii) your use of any such SNS. You can revoke our access to this information anytime by amending the appropriate settings from within your account settings on the applicable SNS.]

c. Cookies. Like many online services, we use Cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). We use two broad categories of Cookies: (i) first-party Cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits the SoHo Jets Platform, and (ii) third-party Cookies, which are served by service providers on the SoHo Jets Platform and can be used by such providers to recognize your computer or mobile device when it visits other websites. SoHo Jets uses Cookies to verify that you are properly signed in, to display information for your primary location, and to provide other information. We may also use Cookies from time to time to measure your response to new aspects of the SoHo Jets Platform and/or emails in an effort to continually improve customer service and the SoHo Jets Platform. Please be aware that a Cookie cannot spread computer viruses, retrieve any other data from your hard drive, or capture your email address.

The SoHo Jets Platform uses the following types of Cookies for the purposes set forth below.

i. Essential Cookies. These Cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the Services and help the content of the pages you request load quickly. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with such services.

ii. Functionality Cookies. These Cookies allow the Services to remember choices you make when you use the Services, such as remembering your language preferences, your login details, and the changes you make to other parts of the Services that you can customize. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to reenter your preferences every time you visit the Site.

iii. Analytics and Performance Cookies. These Cookies are used to collect information about traffic to the Services and how users use the Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to the Services, the websites that referred them to the Services, the pages they visited on the Services, what time of day they visited the Services, whether they have visited the Services before, and other similar information. We use this information to help operate the Services more efficiently, gather broad demographic information, and monitor the level of activity on the Services. [We use Google Analytics] and other third-party analytics services for this purpose. Google Analytics uses its own Cookies. They are only used to improve how the Services works. You can find out more information about Google Analytics Cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

iv. Social Media Cookies. These Cookies are used when you share information using a social media sharing button or “like” button on the Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.

d. Disabling Cookies. You can typically remove or reject Cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help,” “tools,” or “edit” facility). Many browsers are set to accept Cookies until you change your settings. Users must accept Cookies in order to access certain features of the SoHo Jets Platform. You can erase or block Cookies from your computer if you wish to do so (your internet browser help screen or manual will thoroughly explain this process), but certain parts of the SoHo Jets Platform will not work correctly or at all if your browser is set to not to accept Cookies.

e. Pixels. We may also use pixel tags (which are also known as web beacons and clear GIFs) on the SoHo Jets Platform to track the actions of users on our Services. Unlike Cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the SoHo Jets Platform, so that we can manage our content more effectively. With the exception of the Facebook Pixel (see below), the information we collect using pixel tags is not linked to our users’ personal data. SoHo Jets may use the Facebook Pixel to gather information about your activities on the SoHo Jets Platform in order to provide you with tailored SoHo Jets ads. For example, if you sign up for SoHo Jets, you may see a SoHo Jets ad on your Facebook newsfeed. Facebook’s use of information collected is set forth in its Privacy Policy (https://www.facebook.com/policy.php). You may opt out of Facebook’s interest-based ads here: (http://www.facebook.com/about/ads/#568137493302217).

f. Automated decision-making or profiling. We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

4. How SoHo Jets Uses Your Information.

a. Personal Data. In general, we use personal data either to deliver the SoHo Jets Platform or respond to requests that you make. We use your personal data in the following ways:

• Facilitate the creation and securing of your account;

• Identify you as a user of the SoHo Jets Platform;

• Operate, maintain, and provide improved administration of the SoHo Jets Platform;

• Improve the quality of experience when you interact with the SoHo Jets Platform;

• Manage your account, including to send you administrative email notifications such as security or support and maintenance advisories;

• Respond to your comments and inquiries related to employment opportunities or other requests and provide customer service and, with your consent, send newsletters, surveys, offers (including information about products and services offered by us and our affiliates), and other promotional materials related to the SoHo Jets Platform and for other marketing purposes. You may opt out of receiving such information at any time; such marketing emails tell you how to opt out. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us and our business dealings with you;

• Process payments you make via the SoHo Jets Platform;

• As we believe necessary or appropriate (i) to comply with applicable laws; (ii) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (iii) to enforce this Policy; and (iv) to protect our rights, privacy, safety, or property and/or that of you or others; and

• As described in the section titled “HOW SOHO JETS MAY SHARE YOUR INFORMATION” below.

b. Anonymous Data. We may create anonymous data about both users by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of the SoHo Jets Platform. We may use anonymous data and aggregated and other de-identified information for any purpose and disclose anonymous data to third parties in our sole discretion.

5. How SoHo Jets May Share Your Information.

a. With Third Parties Designated by You. We may share your personal data with third parties when you have provided your consent to do so.

b. With Third Parties. We may share your personal data with third-party service providers (“Subprocessors”) to provide you with the SoHo Jets Platform; conduct quality assurance testing; facilitate creation of accounts; provide technical support; conduct data analysis; process payments; provide information technology and related infrastructure provisions, customer service, and email delivery; and/or provide other services. These Subprocessors are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.

You may share personal data with us when you submit user-generated content to the SoHo Jets Platform. Please note that any information you post or disclose on the SoHo Jets Platform will become public information and will be available to other users of the SoHo Jets Platform and to the general public.

We urge you to be very careful when deciding to disclose your personal data, or any other information, on the SoHo Jets Platform. Such personal data and other information will not be private or confidential once it is published on the SoHo Jets Platform. SoHo Jets is not responsible for how others use such information. If you post personal data, even if you later remove it, other individuals who saw that personal data may retain copies of it through means other than the SoHo Jets Platform.

If you provide feedback to us, we may use and disclose such feedback on the SoHo Jets Platform, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on the SoHo Jets Platform. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.

c. With SNS. The SoHo Jets Platform may also enable you to post content to an SNS. If you choose to do this, we will provide information to such SNS in accordance with your elections. You agree that you are solely responsible for your use of an SNS and that it is your responsibility to review the terms of use and privacy policy of such SNS.

d. As Required by Law. We may access, preserve, and disclose your personal data, other account information, and content if we believe doing so is required by law or if those actions are reasonably necessary to:

• Comply with legal process, such as a court order or subpoena;

• Enforce this Policy or our Terms of Service;

• Respond to claims that any content violates the rights of third parties;

• Respond to law enforcement;

• Investigate and prevent unauthorized transactions or other illegal activities; or

• Protect our or others’ rights, property, or personal safety.

e. Corporate Events. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such transaction. We cannot control how such entities may use or disclose such information.

f. Other Disclosures. We may share personal data as we believe necessary or appropriate to (i) comply with applicable laws; (ii) comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) enforce this Policy; and (d) protect our rights, privacy, safety, or property, and/or that of you or others. We may also disclose your personal data with your permission.

6. Third-Party Sites.

The SoHo Jets Platform may contain links to third-party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies, and we do not accept any responsibility or liability for their websites, features, or policies. Please read their privacy policies before you submit any data to them.

7. Security of Your Information.

We seek to use reasonable organizational, technical, and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the section titled “CONTACT INFORMATION” below. By using the SoHo Jets Platform or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the SoHo Jets Platform. If we learn of a breach of personal data, we may attempt to notify you electronically by posting a notice on the SoHo Jets Platform or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us using the details in the section titled “CONTACT INFORMATION” below.

8. Retention.

We will only retain your personal data as long as reasonably required for you to use the SoHo Jets Platform and/or to provide you with the SoHo Jets Platform unless a longer retention period is required or permitted by law (for example, for regulatory purposes).

9. Information about Children.

We do not knowingly collect, maintain, or use personal data from children under thirteen (13) years of age, and no part of the SoHo Jets Platform is directed to children under the age of thirteen (13). If you learn that a child has provided us with personal data without your consent, you must alert us using the details in the section titled “CONTACT INFORMATION” below. If we learn that we have collected any personal data about children under thirteen (13), we will delete such information as soon as reasonably practicable.

10. International Data Transfer.

If you are a non-U.S. user of the SoHo Jets Platform or visitor to the Site, by providing us with data, you acknowledge and agree that your personal data may be processed for the purposes identified in this Policy. Your information, including personal data that we collect from you, may be transferred to, stored at, and processed by us and other third parties outside the country in which you reside, including but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the SoHo Jets Platform, you agree to this transfer, storing, or processing.

11. Sensitive Personal Data.

Subject to the following paragraph, we ask that you not send us, and that you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) (collectively, “Sensitive Personal Data”) on or through the SoHo Jets Platform or otherwise to us.

12. Your Rights.

The following rights may be available to you:

• Opt-out. You may contact us anytime to request to opt out of (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of Sensitive Personal Data; (iv) any new processing of your personal data that we may carry out beyond the original purpose, where we have requested your consent prior to such processing; or (v) the transfer of your personal data outside the EEA, where we rely on your consent for such transfer. Please note that your use of some of the SoHo Jets Platform may be ineffective upon such opting-out.

• Access. You may request to access the information we hold about you at any time via your account page or by contacting us directly.

• Amend. You can also contact us to request to update or correct any inaccuracies in your personal data.

• Move. You may contact us to request that we move your data to other service providers as you wish.

• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in the section titled “CONTACT INFORMATION” below. In your request, please make clear (i) what personal data is concerned and (ii) which of the above rights you would like to request to enforce. We may deny your request when permitted by applicable law. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one (1) month of your request. Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

13. Complaints.

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at info@flysohojets.com. We will reply to your complaint as soon as we can and, in any event, within forty-five (45) days. We hope to resolve any complaint brought to our attention; however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

14. Changes to This Policy.

Any changes to this Policy will always be posted to this section of the Site, along with the effective date of the updated Policy. You should check this page periodically to stay aware of any such changes. For any material changes to this Policy, we will notify Users via email or by placing a prominent notice on the homepage of the Site.

15. Contact Information.

We welcome your comments or questions about this Policy. Please use the “Contact” link of the SoHo Jets Site, or contact us at info@flysohojets.com.