Last updated:26 Jun,2019
Juneyao Airlines Co. Ltd. (“Juneyao Airlines” or “we”, “us”, “our”) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our Ticket Sales System, which includes but is not limited to sales system authorized to be used by the agents, Juneyao Airlines’ Direct Selling System, Juneyao Airlines’ Websites at https://global.juneyaoair.com/ , Juneyao Airlines’ Apps, as well as personal information that we collect when you use our services ("Services") such as booking travel with us.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
This notice contains the following contents for your reference:
1. What personal information does Juneyao Airlines collect and why?
2. Who does Juneyao Airlines share your personal information with?
3. Rules for the use of your personal information
4. Legal basis for processing and cancelling personal information
5. Cookies and similar tracking technology
6. How does Juneyao Airlines keep your personal information secure?
7. International data transfers
8. Data retention
9. Your data protection rights
10. Updates to this Privacy Notice
11. Contact us
What personal information does Juneyao Airlines collect and why?
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.
The personal information that we may collect about you broadly falls into the following categories:
I. Information that you provide voluntarily
We may ask you to provide personal information voluntarily such as
- Information related to your identification credentials, including but not limited to name, credential number, birthday, passport expiry date, passport’s place of issue, nationality, and place of residence in order to make reservations, handle any compensation related to luggage or loss, and verify and confirm identification prior to providing any services and products;
- Contact information such as your name, address, telephone number, email address and fax number for the purpose of providing cargo transportation services, online services, and activities and lottery events organized or represented by the company;
- Juneyao Airlines Club account number to acquire travel mileage;
- Flight information services related to airport and travel, such as duty-free sales and travel package; and
- Personal preferences (dining, seat, language) in order to provide any products and/or services requested by customer.
We use this personal information to facilitate your travel, provide you with other goods and Services, to administer our Juneyao Airlines Club loyalty programme, and to provide you with information about us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Some of the personal information that you provide may include sensitive personal information, such as health-related information or information about your race or ethnicity, which we need for to improve our service provided to you and protect your own interests. We will request your consent when we ask you to provide your sensitive personal information.
II. Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
III. Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
The types of information we collect from third parties include travel professionals, and others who assist in booking and arranging travel. We use the information we receive from these third parties to provide services to you and maintain the accuracy of the records we hold about you.
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
Who does Juneyao Airlines share your personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of our Services or to provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- to other airlines, such as our Star Alliance, interline and codeshare partners, which furnish you with access to VIP airport lounges, perform part of the carriage, or assist with rebooking your flight should any disruption of your itinerary occur; We only share data with these airlines to the extent it is necessary for the performance of a contract with you.
- to third parties, such as employers and travel professionals, who have arranged for discounts, purchase travel or provide other services on your behalf. We only share data with these third parties to the extent it is necessary for the performance of a contract with you.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
Rules for the use of your personal information
We use the personal information collected in accordance with the terms of this Privacy Notice 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 notice, we will ask you for your consent prior to any action.
Legal basis for processing personal information (EEA visitors and customers only)
If you are a visitor or customer from the European Economic Area, 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.
Cookies and similar tracking technology
How does Juneyao Airlines keep your personal information secure?
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.
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 Notice, 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.
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.
International data transfers
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 Notice. 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.
Your data protection rights
You have the following data protection rights:
1.If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
2.In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portabilityof your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
3.You have the right to cancel your account of Juneyao Airlines Club. After you cancel the account, we will stop providing you with the relevant products and/or services, and delete your personal information according to your request unless otherwise stipulated by laws and regulations. You can contact us by way using the contact details provided under the “How to contact us” heading below.
4.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.
5.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.
6.You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, 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 Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
If you have any questions or opinions upon any contents or issues specified in this Privacy Notice, please contact our DPO via following methods.
(1) Contact number: 021-95520/021-22388023
(2) E-mail: firstname.lastname@example.org
(3) Shanghai Juneyao Airlines, No. 80 Hongxiang Third Road, Minhang District, Shanghai, China, 200123