This Privacy Policy sets out how APEX JET HOLDINGS LIMITED (“Apex”, “we”, “us”, or “our”) collects, stores, uses and discloses your personal information in accordance with our obligations under the Privacy Act 2020. It also explains your rights to access and correct personal information held by us.
We recognise that clients who use Private Aviation Services expect the highest standards of professionalism, discretion and confidentiality. Protecting your personal information is fundamental to the services we provide. We are committed to collecting, using, storing and disclosing your personal information responsibly, transparently and in accordance with the Privacy Act 2020.
In this Privacy Policy, when we say:
- “personal information” means identifiable information about you, including your name, residential or business address, email address, telephone number, date of birth, passport details, travel information, payment information, identification documents and any other information relating to you.
- “Apex” means APEX JET HOLDINGS LIMITED together with any special purpose vehicle established by it from time to time to own, lease or operate aircraft used in connection with our Private Aviation Services, including (without limitation) APEX ZK-JCJ Limited, APEX ZK-WLF Limited, and any successor or additional aircraft-owning entities established in the future.
- “GCH Aviation” means GCH Aviation Limited, our aircraft management, maintenance and charter operations provider.
- “Private Aviation Services” means the aircraft charter, aircraft management, concierge, flight support and other aviation-related services provided by or on behalf of Apex from time to time.
- “you” means any individual who engages with us or whose personal information we collect in connection with the provision of our services, including clients, passengers, authorised representatives, employees of corporate clients, prospective clients and visitors to our website.
By engaging with us, requesting or booking our services, communicating with us, or otherwise providing personal information to us, you acknowledge that your personal information will be collected, used and disclosed in accordance with this Privacy Policy.
We may update this Privacy Policy from time to time to reflect changes in our business, our services, technology, legal requirements or privacy practices. Any updated version will be published on our website or otherwise made available to you and will apply from the date it is published or notified.
If you do not agree with any aspect of this Privacy Policy, please notify us before providing us with your personal information.
What information we collect, why we collect it, and who we may share it with
The personal information we collect depends on the nature of your engagement with us and the services we provide.
Clients and Passengers
If you enquire about, arrange or use our Private Aviation Services, we may collect personal information including:
- your contact details (such as your name, residential or business address, email address and telephone number);
- identification information (including copies of passports, driver’s licences or other identification documents);
- date of birth, nationality and citizenship information;
- passport, visa and immigration information where required for domestic or international travel;
- passenger manifest information;
- emergency contact details;
- payment and billing information;
- travel itineraries and flight preferences;
- baggage information where relevant to operational or regulatory requirements;
- catering preferences, dietary requirements or accessibility requirements;
- information relating to health or mobility where reasonably required to safely provide our services;
- information required to comply with aviation, customs, immigration, biosecurity, sanctions, anti-money laundering or other legal obligations;
- communications between you and Apex;
- information relating to your use of our services; and
- any other information reasonably required to arrange, administer and provide our Private Aviation Services.
Certain personal information we collect may be sensitive in nature, including information relating to health, accessibility requirements or identity documentation. We will only collect sensitive personal information where reasonably necessary to provide our services, ensure passenger safety, comply with applicable legal obligations or where you have chosen to provide that information to us.
We collect this information so that we can:
- arrange and administer Private Aviation Services;
- identify and verify clients and passengers;
- prepare passenger manifests;
- coordinate flight operations with GCH Aviation;
- comply with aviation safety and operational requirements;
- arrange airport access, ground handling and other operational services;
- comply with customs, immigration, border security and biosecurity requirements;
- provide concierge or ancillary services requested by you;
- communicate with you regarding bookings, itineraries and flight updates;
- process payments and administer your account;
- maintain appropriate operational and business records;
- respond to emergencies or incidents;
- comply with our legal and regulatory obligations; and
- protect and enforce our legal rights and interests.
We may disclose your personal information to the following persons where reasonably necessary to provide our services, comply with legal obligations, or protect our legitimate interests:
- GCH Aviation, as our aircraft management, maintenance and charter operations provider;
- pilots, flight crew and operational personnel involved in providing your flight;
- airport operators, fixed base operators (FBOs), ground handling providers and other aviation service providers;
- the Civil Aviation Authority of New Zealand and other aviation regulators;
- Airways New Zealand and air navigation service providers where operationally required;
- the New Zealand Customs Service, Immigration New Zealand, the Ministry for Primary Industries and equivalent overseas border agencies;
- overseas aviation, customs, immigration and border authorities where your travel involves another jurisdiction;
- emergency services where reasonably necessary to protect the health or safety of any person;
- our insurers, insurance brokers and claims advisers;
- GCH Aviation’s insurers, insurance brokers and claims advisers where reasonably necessary in connection with the operation of a flight, an incident, accident or insurance claim;
- banks, payment providers, insurers, professional advisers and other service providers engaged in connection with the provision of our services;
- providers of information technology, communications, secure electronic storage and other business support services; and
- any other person where disclosure is authorised by you or required or permitted by law.
We will only disclose your personal information to the extent reasonably necessary for the purpose for which it was collected or for a directly related purpose.
Additional terms about the collection and use of your personal information
In addition to the purposes described above, we may collect and use your personal information to:
- communicate with you by email, telephone, messaging applications, video conference, post or other communication methods regarding our services;
- administer enquiries, quotations, bookings, flight schedules and travel arrangements;
- coordinate services with GCH Aviation and other service providers involved in the operation of your flight;
- verify identities and undertake compliance, sanctions, anti-money laundering or other regulatory checks where required;
- maintain records relating to enquiries, bookings and completed services;
- improve our services, website functionality and client experience;
- manage our business operations, including accounting, auditing, insurance, risk management and internal administration;
- respond to enquiries, complaints or feedback;
- investigate incidents, accidents or potential breaches of law;
- establish, exercise or defend legal claims; and
- otherwise facilitate the provision and administration of our Private Aviation Services.
We may also disclose your personal information where we reasonably believe disclosure is necessary:
- to comply with any applicable law, regulation, court order or lawful request from a governmental or regulatory authority;
- to comply with the requirements of the Civil Aviation Authority, customs, immigration, border security, biosecurity or other aviation-related authorities;
- to protect the safety, security or wellbeing of our clients, passengers, crew or the public;
- to investigate, prevent or respond to fraud, unlawful conduct or security incidents;
- to investigate, defend or resolve legal proceedings, insurance claims, incidents or accidents;
- to protect or enforce our legal rights, contractual rights or property;
- in connection with the sale, transfer or restructuring of our business or assets; or
- where otherwise permitted or required under the Privacy Act 2020.
If you choose not to provide your personal information
Providing your personal information to us is voluntary. However, if you choose not to provide the information we request, we may be unable to:
- assess or respond to your enquiry;
- arrange or provide our services;
- verify your identity;
- comply with aviation, customs, immigration or other regulatory requirements;
- process payments;
- communicate effectively with you regarding your booking; or
- otherwise provide you with the level of service you have requested.
Certain information is required by law or by aviation regulators before a flight can operate. If that information is not provided, we may be unable to proceed with your booking.
How we collect information
We will usually collect your personal information directly from you.
Depending on the nature of the services we provide, we may also collect personal information from:
- your authorised representative;
- your personal assistant, executive assistant or family office;
- your employer or corporate travel coordinator;
- GCH Aviation;
- airport operators or aviation service providers;
- payment providers;
- professional advisers acting on your behalf;
- publicly available sources;
- government or regulatory agencies; or
- any other person authorised by you or otherwise permitted by law.
We may also collect information about your use of our website through cookies, website analytics tools and similar technologies.
Cookies and Website Analytics
When you visit our website, we may collect information about your use of the website through cookies, website analytics tools and similar technologies.
Cookies are small text files stored on your device which help us improve website functionality and your browsing experience.
Your browser settings may allow you to disable or remove cookies. However, doing so may affect the functionality of our website.
We may use third-party analytics services, including Google Analytics or similar services, to better understand how visitors use our website, improve our online services and understand how users interact with our content.
Information collected through these services may be processed by those providers in accordance with their own privacy policies.
You can learn more about Google Analytics by visiting:
http://tools.google.com/dlpage/gaoptout
How we protect and store your information
We take the protection of your personal information seriously and will take reasonable technical and organisational measures to protect it against loss, misuse, unauthorised access, disclosure or alteration.
Personal information may be stored electronically using secure systems operated by us or by trusted third-party service providers engaged to support our business operations.
We may engage third-party providers to assist with:
- information technology and system administration;
- secure electronic storage and hosting;
- communications;
- payment processing;
- document management;
- cybersecurity;
- customer relationship management systems; and
- other operational and administrative services.
We require our service providers to protect personal information appropriately and to use it only for the purposes for which it is disclosed to them.
However, due to the inherent nature of the internet and electronic communications, we cannot guarantee the security of information transmitted electronically.
Your personal information may be stored or processed outside New Zealand where this is necessary for the provision of our services or by our trusted service providers. Where this occurs, we will take reasonable steps to ensure your personal information is protected by safeguards comparable to those required under the Privacy Act 2020.
We will retain your personal information only for as long as reasonably necessary for the purposes for which it was collected, to comply with our legal obligations, resolve disputes, enforce our agreements, or as otherwise required or permitted by law.
International transfers of personal information
Given the international nature of private aviation, your personal information may be transferred to, stored in, or accessed from jurisdictions outside New Zealand where this is necessary to provide our services or comply with applicable legal or regulatory requirements.
For example, we may need to disclose information to overseas airport operators, customs or immigration authorities, aviation regulators, ground handling providers, aircraft maintenance providers, fuel suppliers or other service providers involved in facilitating your travel.
Where your personal information is transferred outside New Zealand, we will take reasonable steps to ensure it is protected by safeguards that are comparable to those required under the Privacy Act 2020 or otherwise permitted under that Act.
Your rights
You have the right to request access to the personal information we hold about you and to request correction of that information if you believe it is inaccurate, incomplete or out of date.
If you wish to access or correct your personal information, please contact us using the details below. We will respond to your request in accordance with the Privacy Act 2020.
We encourage you to notify us if your personal information changes so that our records remain accurate and up to date.
You can find more information about your privacy rights, and how to make a privacy complaint, on the Office of the Privacy Commissioner’s website at:
Electronic communications
We may contact you using the contact details you provide to us in relation to your enquiries, quotations, bookings, flights, account or other services you have requested.
From time to time, we may also send you information about our services, aircraft availability, service updates, events or other communications that we believe may be of interest to you.
If you no longer wish to receive non-essential communications from us, you may unsubscribe at any time using the unsubscribe facility (where available) or by contacting us directly.
Please note that operational, regulatory, safety-related and booking communications relating to your flights or our services may continue to be sent where necessary, even if you have elected not to receive marketing communications.
Contact us
If you have any questions about this Privacy Policy, or the personal information we hold about you, please contact us.
APEX JET HOLDINGS LIMITED
Email: enquiries@apexjet.co.nz
Telephone: +64 3 741 4846
Address: 73 Grays Road, Yaldhurst, Christchurch, New Zealand
Users outside New Zealand
The personal information we collect may be processed in and transferred between your location and New Zealand.
New Zealand may not have privacy laws that are identical to those in force in your jurisdiction. However, we will handle your personal information in accordance with this Privacy Policy and the Privacy Act 2020.
If you are located outside New Zealand, including within the European Economic Area, you may have additional privacy rights under the laws applicable in your jurisdiction.