Latest Update as of: November 22, 2022
Shanghai Juneyao Air Co., Ltd. (hereinafter referred to as "Juneyao Air" or "we") respects and protects the personal privacy rights of children. In order to better safeguard children's personal information, in addition to the "Juneyao Air Customer Privacy Policy," we provide a separate "Children's Privacy Policy" to explain how we collect, store, use, provide, and protect children's privacy. This also serves to inform children and their guardians about the personal privacy rights of children. This Children's Privacy Policy is a supplement to the "Juneyao Air Customer Privacy Policy." For any content not explicitly covered in this policy, the "Juneyao Air Customer Privacy Policy" shall prevail.
Please note, as a guardian of children (hereinafter collectively referred to as "guardian"), we request your assistance in jointly protecting the privacy of children. Before you or your child uses our products and/or services, please carefully read this policy, especially the sections highlighted in bold. When you fully understand and agree to this policy, you may commence using or allowing your child to use our products and/or services. If you or your child has already used or continues to use our products and/or services or has submitted personal information, it is considered an agreement to collect, store, use, provide, and protect children's personal information according to this policy. If you reject this policy, please stop the operation immediately. However, your child may not be able to continue using our products and/or services.
Any child using our products or services should obtain the prior consent of their guardian. If you are a child, please inform your guardian to read this policy together and seek their consent and guidance before using our products and services.
Definition:
In this policy, "children" refers to individuals under the age of fourteen.
Types and Reasons for Collecting Children's Personal Information:
When you or your child uses our provided products and/or services, we may collect some personal information of children, including but not limited to:
(1) Identity information for booking tickets or ordering other services, including: name, ID card number, birthdate, passport number, passport expiration date, passport issuing place, nationality, place of residence, facial recognition information.
(2) Logistics information used for value-added services such as special pick-up services, including: contact information, phone number, email address, logistics address.
(3) Additional information for children requiring special attention and care, to provide services tailored to actual needs, including: medical history, special needs information.
Additionally, if it is necessary to verify the guardianship relationship while providing services to you or your child, we may also collect identity information (including identification documents, household registration), contact information (including phone number, email), address, and other information needed to determine guardianship.
If you do not provide the above information, your child may not be able to use the relevant services we provide. The services related to children that we provide are continuously updated and developed. If you choose to use other services not covered in the "Privacy Policy" and this policy, and if child information needs to be collected based on such services, we will separately explain the scope, purpose, and usage of information through page prompts, interactive processes, agreement terms, etc., and obtain your consent.
How We Use Children's Personal Information:
We strictly comply with legal regulations and use children's personal information as stated in this policy to provide, optimize our products and/or services, and ensure the privacy and security of children. For more detailed information, please refer to the "Juneyao Air Customer Privacy Policy." If we intend to use children's personal information for purposes not specified in this policy or collect additional children's personal information not mentioned, we will seek your consent separately.
How We Store Children's Personal Information:
a) In general, children's personal information will be stored within China. However, if it involves international flights or other cross-border value-added services, we will comply with effective and applicable legal regulations and the requirements of relevant regulatory authorities to ensure sufficient protection of personal information (including children's personal information).
b) Generally, we will only store children's personal information within the necessary period for providing services and the period required by legal regulations. After the aforementioned periods, we will delete or anonymize children's personal information according to legal requirements.
c) If we terminate services or operations, we will promptly cease activities related to the collection of children's personal information. We will also comply with relevant legal regulations, notify guardians in advance, and delete or anonymize children's personal information after terminating services or operations, except as otherwise stipulated by laws or regulatory authorities.
How We Protect the Security of Children's Personal Information:
To ensure the privacy and security of children, we will take reasonable and necessary measures at the technical level to protect children's personal information. These measures include but are not limited to physical protection, security technology, and management systems to reduce the risk of loss, misuse, unauthorized access, disclosure, and alteration. This includes data encryption during transmission, firewall and encrypted storage, physical access control, and information access authorization control. We have established security procedures to protect children's personal information from unauthorized access, and all children's personal information will be encrypted and stored in internal systems strictly protected by firewalls.
How You Can Manage Children's Personal Information:
(1) Withdrawal of Children's Personal Information:
You have the right to request the withdrawal of your consent for us to process children's personal information. You can contact us through the contact information provided in this policy for withdrawal. We will process it in accordance with relevant legal provisions. Please be aware that once you withdraw your consent, your child may not be able to continue using the products and/or services we provide.
(2) Correction, Deletion, or Cancellation of Children's Personal Information:
To facilitate more convenient access and management of your child's personal information during the use of our products and services and to safeguard the rights of correction, deletion, or account cancellation, you and your child can follow the guidelines in Section 7 of the "Privacy Policy" for your personal information rights. You can also directly contact us through the contact information in this policy.
If our products and/or services cease operations, we will, in accordance with relevant legal regulations, immediately stop activities related to the collection and use of children's personal information. We will notify guardians of the cessation of operations through individual delivery or announcements and delete or anonymize children's personal information involved.
(3) Right to Data Portability:
If you request to transfer children's personal information to a designated personal information processor, please contact us through the contact information provided in this policy.
External Disclosure and Outsourcing of Children's Personal Information:
We will only provide children's personal information to external parties for legitimate, lawful, necessary, specific, and clear purposes with your authorization and separate consent. We will provide only the necessary children's personal information for the products and/or services. Additionally, we will assess the legitimacy, lawfulness, necessity, and impact on children's rights when providing children's personal information to third parties. If outsourcing to a third party is truly necessary, we will take compliance measures according to legal regulations, including but not limited to security assessments of third parties and signing outsourcing agreements.
Applicability and Updates of This Policy:
We may modify the terms of this policy in a timely manner based on the updates of our products and services and the relevant requirements of legal regulations. After the update of this policy, we will announce it through official websites, App pop-ups, and other channels, and it will take effect immediately, replacing the relevant content prior to this update. After the update, our App will prompt you to confirm and agree to the updated rules on the login page. If you do not agree with the updated content, you should immediately stop using the corresponding services. If you and your child continue to use the products or services we provide, it will be deemed as an agreement to accept the updated content of this policy.
How to Contact Us:
If you have any questions or opinions about our use of your personal information or want to make personal information appeals, please contact our Data Protection and Compliance Officer through the following methods. We will respond to you within 15 working days:
(1) Contact number: 021-95520/021-61988709
(2) Email address: dpo@juneyaoair.com
(3) Contact address: Shanghai Juneyao Air Co., Ltd., No. 2, Lane 2, Kangqiao East Road, Pudong New Area, Shanghai, China, Zip Code: 201210
If there are issues related to third-party services, you can obtain the corresponding contact information through the service page provided by the third party or by contacting us.