Who we are

Solstice Aviation is a private aviation advisory and brokerage service operated by Ewan Marshalsay. We are the data controller for all personal information processed through this website — we decide how and why your information is used.

No data protection officer has been appointed, as we are not legally required to do so. For any privacy question, contact Ewan Marshalsay directly at ewan@solsticeaviation.com.

What information we collect

Information you provide through the enquiry form or by contacting us directly:

  • Name, email address, and phone number
  • Travel route (departure and destination airports or cities)
  • Travel dates, passenger count, and trip type
  • Scheduling flexibility and any additional notes

Information collected automatically, only after you have accepted analytics cookies:

  • Pages visited and time spent on each
  • Buttons and links clicked
  • Device type, browser, and approximate location (country level)
  • Referring source (how you arrived at the site)

We do not collect payment details, passport information, or any special category data through the website.

How we collect it

Most information is collected directly from you when you complete the enquiry form or contact us by email or phone.

Analytics data is collected automatically by PostHog, but only after you have given explicit consent through the cookie banner on your first visit. If you decline, no analytics cookies are set and no behavioural data is recorded.

In some cases, information may be provided by a third party on your behalf — for example, a personal assistant or corporate travel manager submitting an enquiry for a principal or colleague. The person submitting the form is responsible for having authority to share that information with us.

Why we use it and our legal basis

Responding to enquiries

We use enquiry form data to assess your trip, identify suitable aircraft and operators, and respond with a tailored shortlist and follow-up guidance.

The legal basis is legitimate interest (Article 6(1)(f) UK GDPR). You have voluntarily initiated contact to explore a potential charter booking. Processing your enquiry details is the minimum necessary to respond usefully, and is what you would reasonably expect when you submit the form. No automated decision-making or profiling is applied — all assessments are made by a person.

Charter service communications

If you submit an enquiry about a specific trip, we may follow up with information about similar charter services or relevant routes. This is permitted under the PECR soft opt-in rule, which allows direct marketing where an enquiry represents active purchasing intent, an opt-out was offered at collection, and every message includes an unsubscribe option.

You can opt out at any time by replying to any email or contacting us at ewan@solsticeaviation.com.

Site analytics

Where you have consented, we use PostHog to understand how visitors use the site — which pages are helpful, where friction exists in the enquiry journey, and what content supports informed decisions. The legal basis is consent (Article 6(1)(a) UK GDPR, Regulation 6 PECR). You can withdraw consent at any time via the cookie settings on the site.

Who we share it with

We do not sell your information. We share it only where necessary:

  • PostHog — analytics provider. Processes behavioural data on our behalf under a data processing agreement.
  • Resend — email delivery provider based in Ireland. Enquiry form submissions are routed through Resend to reach us. Resend does not use this data for its own purposes.
  • Charter operators — when a trip progresses to active sourcing, we share the minimum information necessary (typically route, dates, and passenger count) with vetted operators to obtain availability and pricing. We do not share your contact details with operators without your knowledge.

We may also disclose information where required by law or to protect legal rights.

International transfers

Both of our primary service providers — PostHog and Resend — process data within the European Union (PostHog on EU infrastructure at eu.i.posthog.com; Resend in Ireland). Transfers from the UK to the EU are covered by the UK–EU adequacy decision, which recognises EU data protection law as equivalent to UK standards.

If you would like details of the specific safeguards in place for any transfer, contact us at ewan@solsticeaviation.com.

How long we keep it

  • Enquiries that do not result in a booking — reviewed and deleted within 12 to 24 months of the last contact, unless you have asked us to retain your details for future trips.
  • Completed bookings — retained for 6 years from the date of the booking, which is the limitation period for contractual claims under English law.
  • Analytics data — governed by PostHog's retention settings. We do not retain raw session data beyond what is needed for aggregate reporting.

You may ask us to delete your information at any time — see below.

Your rights

Under UK GDPR you have the right to:

  • Access — request a copy of the information we hold about you
  • Rectification — ask us to correct inaccurate or incomplete information
  • Erasure — ask us to delete your information where there is no compelling reason to keep it
  • Restriction — ask us to limit how we use your information in certain circumstances
  • Objection — object to processing based on legitimate interest, including direct marketing
  • Portability — receive your information in a structured, machine-readable format where processing is based on consent or contract

To exercise any of these rights, email ewan@solsticeaviation.com. We will respond within 30 days at no charge.

Withdrawing consent

For analytics cookies, you can withdraw consent at any time by declining through the cookie banner or adjusting your cookie preferences. Withdrawing consent does not affect the lawfulness of any processing that took place beforehand.

To withdraw consent for marketing communications, reply to any message we have sent or email ewan@solsticeaviation.com. We will remove you from our list promptly.

How to complain

If you believe we have handled your information incorrectly, please contact us first at ewan@solsticeaviation.com and we will try to resolve it quickly.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

  • Website: ico.org.uk
  • Phone: 0303 123 1113
  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

If you are in the European Union, you may also contact the supervisory authority in your country of residence.

Cookies and tracking

The site uses two categories of cookie:

  • Strictly necessary — required for the site to function, such as preserving your cookie consent preference. These do not require your consent.
  • Analytics — set by PostHog to collect behavioural data as described above. These are only placed after you actively accept them through the cookie banner.

We do not use advertising cookies, social media tracking pixels, or any remarketing technology.

Changes to this policy

If we make a material change to how we handle your information, we will update the date at the top of this page. For significant changes, we will add a notice to the website.

Contact

Privacy questions, rights requests, and data-related concerns can be sent to ewan@solsticeaviation.com. We aim to respond within five working days and will meet the statutory 30-day deadline for rights requests.