Privacy Policy

AeroLux d.o.o.

Last updated: May 21, 2026

1. Introduction

AeroLux d.o.o. (“AeroLux”, “we”, “us”, or “our”) is committed to protecting the privacy and personal data of its users, clients, and visitors of the website aerolux.rs (the “Website”).

This Privacy Policy describes what data we collect, how we use it, with whom we share it, what rights you have regarding your data, and how you can exercise them.

This Policy complies with the Personal Data Protection Act of the Republic of Serbia (“Official Gazette of RS”, No. 87/2018), as well as with the General Data Protection Regulation of the European Union (GDPR – Regulation (EU) 2016/679) for visitors from the European Economic Area.

2. Data Controller

The personal data controller is:

  • Name: AeroLux d.o.o.
  • Address: Ugrinovačka 223Dž, 11080 Belgrade (Zemun), Republic of Serbia
  • Tax ID (PIB): 114320530
  • Company Registration Number: 22006045
  • Website: https://aerolux.rs/
  • Email for privacy-related inquiries: info@aerolux.rs

3. What Data We Collect

3.1. Data You Provide to Us

When you submit an inquiry through our contact form, aircraft request form, or contact us via email, phone, or other channels, we may collect the following data:

  • First and last name
  • Email address
  • Phone number
  • Content of the message or inquiry (including destinations, travel dates, number of passengers, and other information relevant to the inquiry)
  • Additional information you voluntarily provide during communication

3.2. Data Collected Automatically

When you visit our Website, we automatically collect certain technical data through cookies and similar technologies:

  • IP address
  • Browser type and version
  • Operating system and device type
  • Pages visited on our Website and time spent on them
  • Referrer URL
  • Approximate geographic location (based on IP address)
  • Interaction data (clicks, mouse movements, scrolling)

4. Legal Basis and Purposes of Processing

We process your personal data on the following legal bases and for the following purposes:

4.1. Performance of a Contract or Pre-Contractual Steps

  • Responding to your inquiries and offers for private aviation services
  • Preparing quotes, arranging flights, and providing information about our services
  • Communication related to a specific request

4.2. Legitimate Interest

  • Improving the quality and functionality of our Website and services
  • Website security and prevention of abuse
  • Internal record-keeping and business analysis
  • Defense of legal claims and exercise of legal interests

4.3. Consent

  • Sending marketing messages and newsletters
  • Use of analytical and marketing cookies
  • Conversion tracking and remarketing activities

You may withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.

4.4. Legal Obligation

  • Compliance with obligations prescribed by the laws of the Republic of Serbia (tax, accounting, and other regulations)
  • Responding to official requests from competent authorities

5. Cookies and Third-Party Tools

Our Website uses cookies and similar technologies to function properly, analyze traffic, optimize user experience, and for marketing purposes.

5.1. Types of Cookies

  • Essential cookies: enable basic Website functionality. These cookies cannot be disabled.
  • Analytical cookies: help us understand how the Website is used (Google Analytics, Microsoft Clarity).
  • Marketing cookies: used to display relevant advertisements and measure the effectiveness of marketing campaigns (Meta Pixel, Google Ads).

5.2. Third-Party Tools We Use

Google Analytics (Google Ireland Limited / Google LLC) – traffic statistics and user behavior on the Website. More info: https://policies.google.com/privacy

Google Ads (Google Ireland Limited / Google LLC) – advertisement display, conversion tracking, and remarketing. More info: https://policies.google.com/privacy

Meta Pixel (Meta Platforms Ireland Limited) – tracking ad conversions, campaign optimization, and displaying targeted ads on Facebook and Instagram. More info: https://www.facebook.com/privacy/policy

Microsoft Clarity (Microsoft Corporation) – user behavior analysis through session recordings and heatmaps. More info: https://privacy.microsoft.com/privacystatement

Email marketing tool – sending marketing messages and newsletters to users who have given consent.

5.3. Managing Cookies

Upon your first visit to the Website, a cookie banner is displayed where you can accept, reject, or configure individual cookie categories. You can change these settings later in your browser settings or through the cookie panel on the Website.

6. Whom We Share Your Data With

We do not sell your personal data to third parties. We may share it with:

  • Data processors providing services on our behalf (website hosting, email servers, CRM, marketing tools, analytics platforms) – only to the extent necessary for providing those services and under contractual confidentiality obligations.
  • Aircraft operators and partners who carry out flights, when necessary for the realization of your inquiry or booking.
  • Competent state authorities and institutions – when required by law or based on an official request.
  • Legal, accounting, and advisory partners – to the extent necessary for providing professional services.

7. Data Transfers Outside the Republic of Serbia and the European Economic Area

Some of the tools we use (Google, Meta, Microsoft) may transfer data to the United States or other countries outside the Republic of Serbia and the European Economic Area. These transfers are carried out with appropriate safeguards, such as Standard Contractual Clauses (SCC) approved by the European Commission and certifications such as the EU-U.S. Data Privacy Framework.

8. Data Retention Period

We keep your data only as long as necessary to fulfill the purpose for which it was collected:

  • Inquiry and communication data: up to 2 years from the last contact, unless a business relationship is established.
  • Client data with completed services: in accordance with statutory retention periods (accounting regulations require retention of up to 10 years).
  • Data for marketing purposes: until consent is withdrawn.
  • Technical data (analytics): in accordance with the default retention periods of the tools (e.g., Google Analytics – typically up to 14 months).

9. Your Rights

In accordance with applicable regulations, you have the following rights regarding your personal data:

  • Right of access – to receive confirmation from us as to whether we process your data and to obtain a copy of that data.
  • Right to rectification – to request correction of inaccurate data or completion of incomplete data.
  • Right to erasure (“right to be forgotten”) – to request the deletion of your data under certain conditions.
  • Right to restriction of processing – to request the restriction of processing in certain cases.
  • Right to data portability – to receive your data in a structured, commonly used, and machine-readable format.
  • Right to object – to object to processing based on our legitimate interest or for direct marketing purposes.
  • Right to withdraw consent – at any time, without affecting the lawfulness of processing before withdrawal.
  • Right to lodge a complaint with a supervisory authority – in Serbia, the Commissioner for Information of Public Importance and Personal Data Protection (www.poverenik.rs); for EU visitors – the supervisory authority in your country of residence.

To exercise your rights, you may contact us at info@aerolux.rs or by mail at our address. We will respond within the statutory deadline, no later than 30 days.

10. Data Security

We take appropriate technical and organizational security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. These measures include SSL/TLS encryption of communication, access control to data, regular system updates, and employee training.

Despite this, no system of data transmission over the internet is absolutely secure, and we cannot guarantee the absolute security of information.

11. Minors

Our services are not intended for minors under the age of 16. We do not knowingly collect data from minors without parental or guardian consent. If we learn that we have collected data from a minor without appropriate consent, we will delete such data.

12. Links to Other Websites

Our Website may contain links to external sites that we do not control. We are not responsible for the privacy policies of such sites and recommend that you read their policies before providing them with your data.

13. Changes to the Privacy Policy

We reserve the right to occasionally amend this Privacy Policy. All changes will be published on this page, with a new last-updated date. In case of significant changes, we will additionally notify you via the Website or email.

14. Contact

For any questions, requests, or complaints regarding personal data protection, feel free to contact us:

  • AeroLux d.o.o.
  • Ugrinovačka 223Dž, 11080 Belgrade (Zemun), Republic of Serbia
  • Email: info@aerolux.rs
  • Web: https://aerolux.rs/