Privacy Policy
1. Controller
Neli Arabi GmbH, Teltower Damm 57, 14167 Berlin, Germany; email: contact@neliarabi.flights.
2. Website access
When you access the website, we process technical connection data to provide and secure the website; the legal basis is Article 6(1)(f) GDPR, and our legitimate interest is the secure and reliable operation of the website and our IT systems.
3. Flight, charter and Empty Leg enquiries
When you submit a flight, charter or Empty Leg enquiry, we process the contact and flight data you provide to handle your enquiry, obtain operator quotations and provide you with a quotation; the legal basis is Article 6(1)(b) GDPR.
Your name, email address and the flight data required for the enquiry are required; without them we cannot process the enquiry, while fields marked optional are voluntary.
4. General contact, aircraft purchase and leasing enquiries
For general contact, aircraft purchase and leasing enquiries, we process the data you provide to respond to your enquiry and, where applicable, take pre-contractual steps; the legal basis is Article 6(1)(b) GDPR and, for other business communications, Article 6(1)(f) GDPR, and our legitimate interest is the handling of business communications.
Information marked as required must be provided so that we can process the enquiry; fields marked optional are voluntary.
5. Bookings
If you accept a quotation and proceed with a booking, we process the passenger, contact, billing and, where required, travel-document data necessary for the booking and performance of the flight; the legal basis is Article 6(1)(b) GDPR and, where processing is required by law, Article 6(1)(c) GDPR.
Information required for the booking and performance of the flight must be provided; without it we cannot arrange the booking or flight.
6. Recipients
Categories of recipients of personal data, where necessary for the relevant purpose, are hosting, IT and email service providers, technical charter-request services, aircraft operators, relevant aviation service providers and competent authorities.
7. Transfers outside the European Economic Area
Hosting, IT or email service providers and recipients required for a booking may process personal data outside the European Economic Area.
For transfers to countries covered by an adequacy decision, we rely on that decision; otherwise, we use the European Commission Standard Contractual Clauses or another lawful mechanism under Chapter V GDPR.
Information about the safeguards used and, where applicable, a copy may be requested at contact@neliarabi.flights.
8. Retention
| Data category | Retention |
|---|---|
| Non-booked flight, charter, Empty Leg and general enquiries, including related enquiry emails | 12 months after closure of the enquiry or the last substantive communication. |
| Our own application/API logs | 30 days; longer only where required for a specific security incident or legal matter. |
| Rolling backups containing personal data | Maximum 90 days; after a restoration, the applicable deletion periods are re-applied. |
| Travel and identity-document data without an independent statutory retention requirement | No later than 30 days after completion of the flight, unless required longer for a specific legal matter. |
| Business, booking and tax records subject to statutory retention | 6, 8 or 10 years depending on the type of record. |
| Other personal data | Until the relevant processing purpose no longer applies, unless a legal obligation or specific legal matter requires longer retention. |
9. Your rights
Subject to the applicable legal requirements, you have the right to access, rectification, erasure, restriction of processing, data portability and objection.
To exercise your rights, contact contact@neliarabi.flights.
You have the right to lodge a complaint with a data protection supervisory authority.