Privacy Policy — JBA – Jet Broker Advisors LDA
Last updated: 11 March 2026
This Privacy Policy explains how
JBA – Jet Broker Advisors LDA (“JBA – Jet Broker Advisors LDA”, “we”, “us”, “our”) collects and processes your personal data when you visit
jetbrokeradvisors.com or contact us through our website forms.
We process personal data in accordance with the
General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Portuguese data-protection laws.
1. Identity and contact details of the controller
Controller:
JBA – Jet Broker Advisors LDA
Rua Humberto Delegado 76
2750-033 Cascais, Portugal
Phone: +351 935 480 802
Email: team@jetbrokeradvisors.com
Website: https://jetbrokeradvisors.com
We have not appointed a Data Protection Officer (DPO), but you can contact us using the details above for any privacy-related questions.
2. What personal data we collect
We only collect personal data that you voluntarily provide when you interact with us, mainly through our website contact forms.
2.1. Data you provide via forms
- Identification data: Name
- Contact details: Email address, phone number
- Content of your message: Any information you choose to include in the free-text fields (e.g., details about your inquiry, company, preferences, etc.)
Please avoid including sensitive personal data (e.g., health data, political opinions, financial account numbers) in free-text fields unless strictly necessary.
2.2. Technical and usage data
Our website may automatically collect limited technical data necessary for security and basic functionality, such as:
- IP address
- Browser type and version
- Device type and operating system
- Date and time of access
- Pages visited and basic interaction logs
We do not use this information to identify you directly, and we do not combine it with other data to create profiles.
3. Purposes and legal bases for processing
We process your personal data only for specific, explicit, and legitimate purposes.
3.1. Responding to inquiries and providing information
Purpose:
- To receive and manage your inquiries submitted via our website forms
- To contact you in response to your request (e.g., information about our services, follow-up questions, potential collaboration)
Legal bases:
- Article 6(1)(b) GDPR — processing is necessary to take steps at your request prior to entering into a contract
- Article 6(1)(f) GDPR — our legitimate interest in responding to inquiries and managing business communications
3.2. Maintaining business records
Purpose:
- To keep internal records of communications with prospects, clients, and partners
- To manage and document our business activities
Legal bases:
- Article 6(1)(f) GDPR — our legitimate interest in maintaining proper business records and ensuring continuity of communication
- Article 6(1)(c) GDPR — where retention is required to comply with legal obligations (e.g., accounting, tax)
3.3. Consent-based processing (if applicable)
If we ever ask for your explicit consent (for example, for certain marketing communications), we will:
- Clearly explain the purpose
- Allow you to freely give or refuse consent
- Allow you to withdraw consent at any time
In such cases, the legal basis is
Article 6(1)(a) GDPR — your consent.
Currently, we do
not use your contact details for mass marketing campaigns unless you explicitly agree.
4. How we collect and store your data
4.1. Collection via website forms
When you submit a form on
jetbrokeradvisors.com, the data you enter is transmitted securely (via HTTPS) and then stored in our internal systems.
4.2. Storage in Google Sheets (Google Workspace)
We store form submissions in
Google Sheets, which is part of
Google Workspace. In this context:
- JBA – Jet Broker Advisors LDA is the data controller
- Google LLC acts as our data processor
Google processes data on our behalf under contractual terms that include data-protection and security commitments aligned with GDPR, including mechanisms for international data transfers (such as Standard Contractual Clauses).
Access to these Google Sheets is restricted to authorized personnel of JBA – Jet Broker Advisors LDA who need the information to perform their tasks.
5. Cookies and similar technologies
At present, our website:
- Does not use cookies for behavioral advertising or profiling
- May use strictly necessary cookies or similar technologies required for basic site functionality and security
If we introduce additional cookies (e.g., analytics or marketing cookies), we will:
- Update this Privacy Policy and/or provide a separate Cookie Policy
- Implement a cookie banner or consent mechanism where required
- Allow you to manage your cookie preferences
6. Data sharing and recipients
We do not sell, rent, or trade your personal data.
We may share your data only with:
- Service providers / processors: Google LLC (Google Workspace, including Google Sheets and related tools) for data storage and communication
- Professional advisors: Lawyers, accountants, or auditors, where necessary and subject to confidentiality obligations
- Public authorities: When required by law, court order, or regulatory obligation
All processors acting on our behalf are bound by contracts that require them to:
- Process personal data only on our documented instructions
- Implement appropriate technical and organizational security measures
- Respect confidentiality and data-protection requirements
7. International data transfers
Because we use Google Workspace, your personal data may be transferred to and stored on servers located outside the European Economic Area (EEA), including in the United States.
Such transfers are protected by appropriate safeguards, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Additional technical and organizational measures implemented by Google
You can contact us if you would like more information about the safeguards in place for international transfers.
8. Data retention periods
We retain personal data only for as long as necessary for the purposes for which it was collected, and in line with legal obligations.
As a general guideline:
- General inquiries and contact form submissions: Typically retained for up to 12–24 months after the last interaction, unless a longer period is justified (e.g., ongoing discussions or potential collaboration)
- Client-related communications and records: Retained for the duration of the relationship and for the period required by applicable law (e.g., accounting and tax rules)
- Technical logs: Retained for a limited period necessary for security, troubleshooting, and performance monitoring
When data is no longer needed, we will delete or anonymize it in a secure manner.
9. Your rights under GDPR
As a data subject, you have the following rights regarding your personal data:
- Right of access: You can request confirmation as to whether we process your personal data and obtain a copy of that data.
- Right to rectification: You can request correction of inaccurate or incomplete personal data.
- Right to erasure (“right to be forgotten”): You can request deletion of your personal data in certain circumstances (e.g., when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent where consent was the legal basis).
- Right to restriction of processing: You can request that we restrict processing of your data in certain situations (e.g., while we verify accuracy or handle an objection).
- Right to data portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and have it transmitted to another controller where technically feasible and where processing is based on consent or contract.
- Right to object: You can object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
- Right to withdraw consent: Where processing is based on your consent, you can withdraw that consent at any time. This does not affect the lawfulness of processing before withdrawal.
To exercise any of these rights, please contact us at:
Email: team@jetbrokeradvisors.com
Phone: +351 935 480 802
We may need to verify your identity before fulfilling your request.
10. Right to lodge a complaint with a supervisory authority
If you believe that your data-protection rights have been violated, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.
In Portugal, the competent authority is:
Comissão Nacional de Proteção de Dados (CNPD)
Website:
https://www.cnpd.pt
We would, however, appreciate the chance to address your concerns first, so we encourage you to contact us directly before approaching the CNPD.
11. Security of your personal data
We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
These measures include, among others:
- Use of secure connections (HTTPS) for our website
- Restricted access to personal data on a need-to-know basis
- Secure use of Google Workspace (including access controls and authentication)
- Internal practices aimed at minimizing data collection and retention
While no system can be guaranteed to be 100% secure, we continuously review and improve our security measures.
12. Children’s data
Our website and services are not directed at children under
16 years of age, and we do not knowingly collect personal data from minors.
If you believe that a child has provided us with personal data, please contact us so that we can delete such data where appropriate.
13. Links to other websites
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties.
We encourage you to read the privacy policies of any external sites you visit.
14. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or website functionality.
When we make changes, we will:
- Post the updated version on this page
- Update the “Last updated” date at the top of the policy
We encourage you to review this Privacy Policy periodically.