Personal information refers to various information recorded electronically or otherwise that can be used alone or in combination with others to identify a natural person or reflect the activity of a natural person.

Personally sensitive information refers to personal information that (1) is illegally provided or abused, (2) may endanger the safety of people and property, and (3) if breached, can easily result in damages to personal reputation, physical and/or mental health, or discriminatory treatment，as well as personal information of individuals under the age of fourteen.

The personal information that we may collect about you broadly falls into the following categories:

We may disclose your personal information to the following categories of recipients:

We use the personal information collected in accordance with the terms of this Privacy Policy and for the purpose of implementing our products and/or services. Please note that all personal information you provide when using our products and/or services, or personally sensitive information collected with your consent, will be continuously used by us during your use of our products and/or services unless you delete your account, revoke your consent or reject our collection through system settings. We will stop using and delete this information when you revoke your consent or cancel your account.

We collect statistics on the use of our products and services and may share this information with the public or third parties to demonstrate the overall usage of our products and services. However, such statistics do not contain identifying information.

We will de-identify any personal information displayed in such manner, including the use of content replacement and anonymity to protect your information.

When we want to use your personal information or collect information for purposes not specifically covered by this policy, we will ask you for your consent prior to any action.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. 

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our company and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our products and services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we taken include Secure Socket Layer (SSL) encryption technology and access control to ensure the secure transmission of your data from your browser to our network systems.

We will take all reasonable and practicable steps to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period of time required to achieve the purposes stated in this policy, unless an extension of the retention period is required or permitted by law. Your personal information will be deleted or anonymised after the retention period.

Unless otherwise provided by laws and regulations, we will retain your personal information until one month after the date of your account cancellation. We promise that this is to ensure the shortest period necessary for the protection of your consumer rights. When your personal information exceeds the retention period we set, we will delete or anonymize your personal information.

If we terminate service or operation, we will notify you at least 30 days in advance and delete or anonymise your personal information after termination of service or operation.

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in the People's Republic of China, and our group locations and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group locations, which require all group locations to protect personal information they process from the EEA in accordance with European Union data protection law. 

Our Standard Contractual Clauses can be provided on request.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

At any time you have the right to exercise your rights under applicable laws and regulations:

1) Right of access:You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – in particular – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed.

You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.

2)Right to rectification:You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

3)Right to erasure (right to be forgotten):You have the right to ask us to erase your Personal Data.

4)Right to restriction of processing:You have the right to request that we restrict the processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

5)Right to data portability:You have the right to request to receive your Personal Data in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another company without hindrance from us.

6)Right to object: You have the right to object, based on your particular situation, at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by us. Exercising this right will not incur any costs.

However, in certain circumstances such a right to object may not exist, e.g. if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

[Please understand that any service feature requires some basic Personal Data before it can be provided. After you exercise your right to object, we will be unable to continue providing the service corresponding to the Personal Data involved in the objection and we will no longer process your corresponding Personal Data.]

7)Right to cancel account:You have the right to cancel a previously registered account at any time. Upon completion of the cancellation of your account, all information therein will be deleted or anonymized and we will no longer collect, use or provide to third parties Personal Data relating to the account.Nevertheless, the information provided by you or generated during the period your use of our services will need to be retained by us for the period required by laws and regulations, and authorities will have the right to access such information according to law during that legal retention period.

8)Right to refuse us to send you promotional information:You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.

Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

9)Right to explain this Privacy Policy:When you have any questions about the rules governing the processing of personal information contained in this Privacy Policy, or about the processing of your Personal Information, or you require us to provide specific information in accordance with applicable law,you may request an explanation by sending an email to dpo@juneyaoair.com. We will respond to individuals' requests concerning their rights related to personal information protection in accordance with applicable laws and regulations on personal information protection. To ensure the security of your personal information, we may request a written request or verification of your identity before providing a substantive response to your request. Once your identity is confirmed, we will respond within 15 working days. However, if objective circumstances prevent us from responding promptly, we will seek your consent to extend the deadline and provide a response within the extended period.

If individuals under the age of fourteen wish to become members, they need to obtain the consent of their parents or other guardians. We will strictly adhere to legal requirements to collect and protect the personal information of minors.

If a minor registers as a member without the consent of their parents or guardians and conceals their identity, we will consider them as an adult member. Parents or guardians of minors can contact us through the information provided under the "How to Contact Us" heading, requesting us to stop providing services to the account of the minor. We will immediately initiate the account cancellation process after verifying the relevant situation and, in accordance with relevant national laws and regulations, delete the member account and related personal information.

If the information you submit involves the personal information of minors (such as commonly used passengers, beneficiaries, and other services), you must obtain the authorization and consent of the parents or guardians of the minors, and ensure that they are aware of and agree to this policy. Otherwise, we have the right to immediately delete such information, and you shall bear the corresponding legal responsibilities.

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. 

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

If you have any questions or opinions upon any contents or issues specified in this Privacy Policy, please contact our DPO via following methods. 

(1) Contact number: 021-95520/021-61988709

(2) E-mail: dpo@juneyaoair.com

(3) Contact Address: Juneyao Air, Lane 2, Kangqiao East Road, Pudong New Area, Shanghai, China, Postal Code: 201210

This Privacy Policy is compiled in Chinese. In the event of any inconsistency or ambiguity between the Chinese version and the translated version, the Chinese version shall prevail.