Flywell Aviation Services

Last updated: June 2026  |  Version 1.0

1. INTRODUCTION AND IDENTITY OF THE CONTROLLER

Flywell, operated by Collin van Well, is an independent aviation services company registered in the Netherlands, based at EHMZ Midden-Zeeland Airport. Flywell provides aircraft brokerage, private jet charter brokerage, aviation real estate consultancy, aircraft detailing, and ancillary aviation services (collectively: the "Services").

This Privacy Policy explains how Flywell collects, uses, stores, shares, and protects personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR") and applicable Dutch implementing legislation (UAVG).

Data Controller:

– Trading name: Flywell

– Operator: Collin van Well

– Address: Banjaardstraat 46, 4456BR Lewedorp, Netherlands (registered address) / Albert Joachimikade 3, 4461BG Goes, Netherlands (office)

– Email: contact@flywell.nl

– KvK (Chamber of Commerce): 97821225

2. SCOPE OF THIS POLICY

This Privacy Policy applies to all personal data processed by Flywell in connection with:

– Use of the Flywell website(s) and any digital platforms operated by Flywell

– Enquiries, negotiations, and transactions related to aircraft brokerage and charter brokerage

– Aviation real estate consultancy mandates

– Aircraft detailing, ground handling, and ancillary service requests

– Communication via email, telephone, WhatsApp, or any other channel

– Relationships with business contacts, vendors, counterparties, and referral partners

3. PERSONAL DATA WE COLLECT

3.1 Data You Provide Directly

– Full name, job title, company name

– Contact details: email address, telephone number, postal address

– Aircraft ownership details, tail numbers, fleet information

– Financial information relevant to a transaction (budget ranges, financing preferences — no payment card data is stored by Flywell)

– Passport or identity document details where required for aviation regulatory compliance or KYC purposes

– Transaction instructions and correspondence

3.2 Data Collected Automatically

– IP address, browser type and version, operating system

– Pages visited, time and date of access, referring URL

– Cookies and similar tracking technologies (see Section 10)

3.3 Data from Third Parties

– Aviation registries and public aircraft databases

– Referral partners and brokers who introduce clients or counterparties

– Publicly available professional profiles relevant to a transaction

4. LEGAL BASIS FOR PROCESSING

Flywell processes personal data on one or more of the following legal bases under Article 6 GDPR:

– Contract performance (Art. 6(1)(b)): Processing necessary to perform a brokerage mandate, charter arrangement, consultancy agreement, or service agreement to which you are a party.

– Legitimate interests (Art. 6(1)(f)): Processing necessary for Flywell's legitimate business interests, including maintaining client relationships, preventing fraud, managing risk, and marketing to existing professional contacts.

– Legal obligation (Art. 6(1)(c)): Processing required to comply with applicable law, including anti-money laundering (WWFT), tax regulations, and aviation safety regulations.

– Consent (Art. 6(1)(a)): Where no other legal basis applies and you have given explicit, freely given consent — for example for marketing communications or non-essential cookies.

5. PURPOSES OF PROCESSING

– Managing and executing aircraft brokerage and charter brokerage mandates

– Identifying and introducing buyers, sellers, lessors, and lessees

– Performing due diligence, KYC, and anti-money laundering checks as required by Dutch law

– Aviation real estate consultancy, including property identification and transaction support

– Scheduling, coordinating, and billing for aircraft detailing and ancillary services

– Issuing invoices, processing payments, and managing accounts

– Maintaining business relationships and communicating with clients and partners

– Sending relevant market updates, aircraft listings, and service information (opt-out available at any time)

– Compliance with Dutch and EU legal and regulatory requirements

– Protecting Flywell's legal rights and interests in any dispute

– Improving our website and digital services through analytics

6. SHARING OF PERSONAL DATA

Flywell does not sell personal data. We may share personal data with:

– Co-brokers, buyer or seller representatives, or other aviation intermediaries strictly to the extent necessary to complete a transaction you are involved in

– Legal, financial, or technical advisors bound by professional confidentiality obligations

– Accountants and auditors for financial record-keeping and compliance

– IT service providers (hosting, CRM, email) acting as processors under GDPR-compliant data processing agreements

– Competent authorities (tax authority, FIU, civil aviation authority) where required by law

Any third party receiving personal data is required to handle it in accordance with applicable data protection law. Flywell uses standard contractual clauses or equivalent safeguards for any international transfers outside the EEA.

7. RETENTION PERIODS

– Client and transaction data: 7 years from the end of the business relationship (Dutch tax and accounting obligations)

– Anti-money laundering and KYC records: 5 years from the end of the business relationship (WWFT Article 33)

– Marketing contact data (consent-based): until withdrawal of consent or upon request

– Website analytics data: maximum 26 months

– Correspondence: 5 years unless subject to a longer statutory retention period

After the applicable retention period, data is securely deleted or anonymised.

8. YOUR RIGHTS UNDER THE GDPR

You have the following rights with respect to your personal data:

– Right of access (Art. 15): Request a copy of the personal data Flywell holds about you.

– Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.

– Right to erasure (Art. 17): Request deletion of your personal data where no longer necessary, subject to legal obligations.

– Right to restrict processing (Art. 18): Request that we limit how we use your data in certain circumstances.

– Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.

– Right to object (Art. 21): Object to processing based on legitimate interests, including direct marketing.

– Right to withdraw consent (Art. 7(3)): Where processing is based on consent, you may withdraw at any time without affecting prior lawful processing.

To exercise any of these rights, contact: contact@flywell.nl. We will respond within one month. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): www.autoriteitpersoonsgegevens.nl.

9. DATA SECURITY

Flywell implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Measures include encrypted communications, access controls, GDPR-compliant processors, and regular security reviews.

In the event of a personal data breach likely to result in a high risk to your rights and freedoms, Flywell will notify you without undue delay in accordance with Article 34 GDPR.

10. COOKIES AND TRACKING TECHNOLOGIES

– Strictly necessary cookies: Required for the website to function. Cannot be disabled.

– Analytical/performance cookies: Used to understand website usage. Only placed with consent.

– Marketing/tracking cookies: Used to deliver relevant content. Only placed with explicit consent.

You can manage or withdraw cookie consent at any time through your browser settings or the cookie preference centre on our website.

11. MINORS

Flywell's services are directed exclusively at professionals and adults. We do not knowingly collect personal data from persons under the age of 18. If we become aware that personal data of a minor has been collected, we will delete it promptly.

12. CHANGES TO THIS PRIVACY POLICY

Flywell may update this Privacy Policy from time to time. The current version will always be available on our website. Material changes will be communicated to existing clients by email. Continued use of our services after notification constitutes acceptance of the updated policy.

13. CONTACT

– Email: contact@flywell.nl

– Address: Flywell, Banjaardstraat 46, 4456BR Lewedorp, Netherlands (registered address) / Albert Joachimikade 3, 4461BG Goes, Netherlands (office)

– Website: www.flywell.nl

This document does not constitute legal advice. Flywell recommends periodic review by a qualified legal professional.

© 2026 Flywell. All rights reserved.​www.flywell.nl