Privacy Policy of Shandong Airlines

The latest update as of [January 20, 2022]

Shandong Airlines Co., Ltd. (hereinafter “we” or “us”) fully understands the importance of personal privacy, and we will take corresponding security protection measures in accordance with laws and regulations to keep your personal information secure and controllable with our best efforts. We would like to use this Privacy Policy to introduce how we collect, use, save, share and transfer your information during your use of our products and/or services, and how we allow you to access, update, delete and protect such information.

This Privacy Policy will help you to understand the following content:

1. How we collect and use your personal information

2. How we use Cookies and similar technology

3. How we share, transfer and publicly disclose your personal information

4. How we protect and save your personal information

5. Protection of information of minors under the age of 14

6. Your rights

7. Revision of privacy policy

8. How to contact us

This Privacy Policy applies to products or services provided by Shandong Airlines including seat reservation and ticket booking, passenger and luggage transport, additional services such as insurance, and Phoenix Miles frequent flyer program. Its should be especially noted that this Policy does not apply to third-party services.

Before using the products or services of Shandong Airlines, please read carefully and fully understand this Policy. By using our products or services, you confirm that you have fully understood and agree to this Policy. If you have any questions, opinions or suggestions concerning the content of this Policy, please contact us by calling our customer service at 95369 or sending an email to b2czb@sda.cn.

I. How we collect and use your personal information

One. We will collect and use the personal information you provided voluntarily for the following purposes:

1. Performance of your air transportation contract with us:

 (1) Seat reservation and ticket booking services

In order to guarantee successful airline reservation and legitimate travel, you are required to provide the following information: passenger’s name, gender, date of birth, valid ID (for residents of mainland China, the types of valid ID include resident identity card, temporary identity card, passport, certificate of military officer, certificate of civilian cadre, certificate of compulsory serviceman, certificate of noncommissioned officer, certificate of civil service worker, certificate of employee, certificate of armed police officer, certificate of armed police soldier, and certificate of seaman; for mainland China residents under the age of 16, the types of valid ID also include medical certificate of birth, permanent residence booklet, and identification issued by the local public security organ of the registered permanent residence; for residents of Hong Kong or Macao Region, Mainland Travel Permit for Hong Kong and Macao Residents; for residents of Taiwan Region, Mainland Travel Permit for Taiwan Residents and Residence Permit for Hong Kong, Macao and Taiwan Residents; for foreigners, valid passport, certificate of diplomatic staff stationed in China issued by the Ministry of Foreign Affairs, foreigner’s permanent residence card, and other valid IDs acceptable for flight), nationality, issuing country, certificate’s term of validity, travel time, and contact’s name, mobile phone number and email address.

To complete payment, the following payment information should be provided: bank card number, expiration date, CVV, cardholder’s name, mobile phone number registered with the bank, valid ID information, financial account, and mileage payment password. You should understand that we need to share the following information with the payment institution of your choice: your order number, transaction amount, and other transaction information requested by the payment institution of your choice. After completion of ticket booking, we will generate your order information, including your seat reservation record, ticket number, flight number, origin, destination, flight time, and cabin class.

To have your itinerary mailed, you need to provide the recipient’s name, mobile phone number and mailing address. To issue an electronic invoice, you need to provide your ticket number or valid ID information, name, and mobile phone number or email address; if an invoice title is needed, you should also provide the company name and taxpayer's registration number.

 (2) Registration and use of member services at the official website of Shandong Airlines

To use our member services, you need to provide your name, nationality, ID number, gender, date of birth, mobile phone number, email address and member password for member registration and login.

When adding frequent passenger information for the convenience of quick booking, you need to provide: name, mobile phone number registered with the bank, valid ID (for residents of mainland China, the types of valid ID include resident identity card, temporary identity card, passport, certificate of military officer, certificate of civilian cadre, certificate of compulsory serviceman, certificate of noncommissioned officer, certificate of civil service worker, certificate of employee, certificate of armed police officer, and certificate of seaman; for mainland China residents under the age of 16, the types of valid ID also include medical certificate of birth, permanent residence booklet, and identification issued by the local public security organ of the registered permanent residence; for residents of Hong Kong or Macao Region, Mainland Travel Permit for Hong Kong and Macao Residents; for residents of Taiwan Region, Mainland Travel Permit for Taiwan Residents and Residence Permit for Hong Kong, Macao and Taiwan Residents; for foreigners, valid passport, certificate of diplomatic staff stationed in China issued by the Ministry of Foreign Affairs, foreigner’s permanent residence card, and other valid IDs acceptable for flight), nationality, issuing country, certificate’s term of validity, etc.

 (3) Registration and use of Phoenix Miles member services

If you choose to register as a Phoenix Miles member, you need to provide your name, contact number, valid ID information, country/region, date of birth and password, and we will provide to you your Phoenix Miles membership card number and your membership grade. During the use of your Phoenix Miles membership, your mileage accrual and redemption information will be generated, including your Phoenix Miles mall order records, and your membership grade may change according to the membership grade rules.

In certain processes, you must provide other information so that we can handle your registration and follow-up processes, e.g., face recognition. We may collect your facial image, eigenvalues for face recognition, valid ID information and Phoenix Miles membership card number. If you are a Phonics Junior member or VIP member, we will may your membership card to you, which requires the collection of your contract address. If you are a minor under the age of 14, you will need to provide the associated card number of your guardian. Besides, you can also provide other information voluntarily, such as email address, hobby and preference. To save you the trouble of entering information, we will extract certain information directly from the application form or in the processing flow, including your registration date, registration channel, preferred language of communication, and membership brand. You may redeem your mileage for award tickets for you and your assignees, which requires you to provide necessary information for seat reservation and ticket booking services.

You can also redeem your mileage for commodities in the Phoenix Mall or offline cooperation scenarios, which requires you to provide the recipient’s name, contact number and mailing address. You may also voluntarily provide frequent contact information and frequent recipient information. We will send your recipient information to relevant merchant in the Mall and the logistics service provider; if we cannot reach the recipient, we may also provide your contact information to the merchant. When you redeem your mileage for commodities in offline cooperation scenarios, we will send your order information and membership card number to the cooperative service provider; any customer service issues will be forwarded to the cooperative service provider for handling, and we may provide your contact information to the cooperative service provider.

By participating in membership products, activities and payment by mileage function (both online and offline), and mileage reward and promotions provided by our business partners, you agree to our collection and use of your name, ID information, contact number, email address, mileage information and membership information for the purposes of statistics and member services.

 (4) Real-name authentication service

In order to use our real-name authentication service, you should provide your face information, bank card information, mobile phone number, name and ID number. Regarding the collection of biometric information and consent to authorization, please refer to Authorization for Use of Face Information. Your face information and bank card information will only be verified once, and will not be stored by Shandong Airlines.

 (5) Other services

In order to purchase prepaid luggage, check in, use irregular flight service, have your ticket verified, etc., you need to provide your ticket number or valid ID information, name, mobile phone number, flight number, and flight date. In particular, for refund of irregular flight ticket, the passenger’s card number should also be provided.

To make a hotel reservation, you need to provide the guest’s name, mobile phone number, ID number and check-in/check-out date.

To purchase an insurance policy, you need to provide departure date, return date, insurance period, and the applicant’s name, date of birth, ID number and mobile phone number.

To book a tour, you need to provide the tourist’s name, mobile phone number, ID number, travel time, and contact’s name, valid ID and mobile phone number. For domestic tours, you need to provide the tourist’s Chinese and English names, gender, nationality, passport number and expiration date, date of birth, ID photo, travel time, and contact’s name, valid ID, mobile phone number and email address.

If you are unable to travel due to illness and apply for free cancellation, we will need you to provide a medical certificate for verification.

 (5) Telephone service

We will use your account information and order information for telephone customer service and after-sale service. To guarantee your account security, our call center customer service and online customer service will verify your identify with your account information. When you need request customer service and after-sale service relating to your order information, we will query your order information. In order to contact you conveniently and help you to solve problems quickly or record the handling methods and results of relevant problems, we may save your communication with Shandong Airlines, correspondence/call records and relevant content (including account information, order information, other information provided by you to prove relevant facts, or your contact information). If you are consulting on, complaining about or offering suggestions on a specific order, we will use your account information and order information. When communicating with our customer service staff, you may provide other information in addition to the above information (for example, when you request us to change shipping address, contact person or mobile phone number).

If you need to apply for services including stretcher, wheelchair, unaccompanied minor, carry-on portable oxygen apparatus or ventilator, and transportation of human organs for donation, you need to provide your name, contact method and valid ID information, and relevant companion or guardian’s contact information and address, and we will verify your medical certificate, or collect relevant supporting documents according to the state requirements.

If you are unable to travel due to illness and apply for free cancellation, we will need you to provide a medical certificate for verification.

 (6) Necessity for guaranteeing transaction security

In order to enhance system security during your use of our products and/or services, and improve the accuracy of phishing site fraud prevention and account security protection, we may analyze your browsing information, order information and equipment information (IP address, equipment model and equipment identification number) to judge your account security/transaction security risks and prevent fraud.

We may also collect your equipment information for analyzing Shandong Airlines system problems, traffic statistics, screening for potential risks, and troubleshooting when you choose to send us abnormal information.

In addition, when you revise key personal information and click real-name authentication, you will be requested to verify your identity with mobile-phone operator, face recognition and bank card authentication, and we will confirm your membership with your name, ID number, mobile phone number and bank card information through telecom operator and UnionPay to guarantee your account security. Technical support for mobile-phone operator verification is provided by Guizhou ChinaDataPay Network Technology Co., Ltd. and Qingdao Chengweixin Zhengxin Co., Ltd. Technical support for face recognition is provided by Beijing Linkface Technology Co., Ltd. Technical support for bank card authentication is provided by Guizhou ChinaDataPay Network Technology Co., Ltd.

Two. You can choose whether to authorize us to collect and use your personal information under specific circumstances

For better service experience, we may collect and use your personal information for the additional functions below. 

If you refuse to provide your personal information, you can still use basic functions such as seat reservation and ticket booking, but you may need to provide certain information repeatedly. The additional functions include:

1. Location-based personalized recommendation function: obtain general location, and obtain specific location to find out the airport where the user is at.

2. Camera-based additional functions: we access your camera so that you can use it to scan codes and take photos for real-name authentication and face recognition, participate in marketing activities, and upload a custom avatar or refund voucher.

3. Additional functions based on image unloading: we access your photo album so that you can select and upload photos, images or videos in your cellphone, change your profile picture, and illustrate the problems you encountered when communicating with our online customer service.

4. Additional functions based on voice technology: we access your microphone so that you can inquire flight information by voice.

5. Additional functions based on address book information: we access your address book so that you can extract your contact information more conveniently when booking tickets, saving the trouble of manual input of contact information from your address book.

6. Convenient service based on phone calls: we obtain the permission for phone calls to save you the trouble of manual input of phone number when you need to call our customer service hotline.

The above additional functions may require you to allow us to access your geographic location (location information), camera, photo album (gallery), microphone and address book and give us permission to make phone calls, to realize the collection and use of relevant information.

You can decide to grant or deny us permission any time (we will guide you to change your settings in your equipment system). For instance, you can enable or disable face recognition function to realize autonomous control. When having your identity authenticated and selecting a service, you can voluntarily choose to consent to or cancel authentication.

Please make sure you have obtained adequate third-party authorization when providing third-party information and sensitive information, and ensure that your operation does not violate any lawful third-party rights; meanwhile, you should guarantee that the third party can process its data following the Privacy Policy. When the third party requests deletion or correction of relevant information, you should delete or correct the above information promptly, otherwise you shall bear the legal consequences arising therefrom. If we are changing the intended use of third-party information due to business needs, we will notify you promptly, and please decide whether the processing of the above information can continue according to the third-party authorization.

Besides, by following us on social media platforms including WeChat and Weibo, you are giving us an effective consent to identify you as a follower and the time of following. We shall only use your information to interact with you on the platform, and you can withdraw your consent any time by stopping to follow us.

Two. Indirect collection of personal information

For purposes including completing identity check, guaranteeing transaction security and providing after-sale services, we may obtain your personal information from third parties under certain circumstances (e.g., when you book tickets through the flagship store or an agency on a third-party platform). If your personal information is indirectly obtained from a third-party channel, according to our agreement with the third party, we will use your personal information in compliance with relevant laws and regulations after determining the legitimacy of the source of information.

Three. Exceptions to informed consent

According to relevant laws and regulations, informed consent is not required to collect your personal information under the following circumstances:

1. Necessary for the conclusion and performance of contract according to your requirements;

2. Necessary for the fulfilment of statutory duties or statutory obligations;

3. Necessary for coping with public health emergencies or protecting natural person’s life, health and property security under emergencies;

4. Processing personal information within a reasonable scope to implement behaviors including news coverage and supervision by public opinion for public interest;

5. Processing personal information disclosed by the person himself/herself or other lawfully disclosed personal information within a reasonable scope according to the terms of this Policy;

6. Other circumstances prescribed by laws and administrative regulations.

If Shandong Airlines ceases to offer its products or services, we will stop activities collecting your personal information, notify you of our discontinuation of operations by one-to-one notification or public notice, and delete all personal information held by us from this application.

Four. Circumstances of obtaining personal information from a third party

For purposes including completing identity check, guaranteeing transaction security and providing after-sale services, we may obtain the personal information you shared with third parties with authorization. If your personal information is indirectly obtained from a third-party channel, according to our agreement with the third party, we will use your personal information in compliance with relevant laws and regulations after determining the legitimacy of the source of information.

For instance: you can book tickets through the flagship store of Shandong Airlines or an online agency on a third-party platform. According to our agreement with the third party, we will use your personal information in compliance with relevant laws and regulations after determining the legitimacy of the source of information.

Besides, please note that the third party may have its own privacy policy to explain its collection and use of your personal information, and such privacy policy does not constitute a part of this Privacy Policy. Please read carefully before you decide to consent to its privacy policy.

Five. Rules for using your personal information

According to the terms of this Privacy Policy, we will use the personal information collected for realizing our products and/or service functions. Please note that during your use of our products and/or services, you are continuing to authorize us to use all of the personal information you provided during your use of our products and/or services or the sensitive personal information collected based on your separate consent, unless you delete, withdraw consent or refuse our collection in system settings. Upon your withdrawal of consent or cancellation of account, we shall stop using and delete your personal information stored in this application.

Six. About third-party links

Our website may contain links to websites owned and/or operated by third parties. We have no right to manage and is not responsible for the content or privacy protection practices of such websites. We recommend that you read the applicable privacy policy carefully before using such third-party websites or providing any personal information to such third parties.

II. How we use Cookies and similar technology

When you use our website, we may collect trace information, such as the type of your browser, the type of operating system, the name of your Internet service provider and the webpages you visited on our website. To improve the functions and usability of our website, Shandong Airlines uses multiple technologies including cookies and web beacons to access such information, so that our websites, products and services can meet your needs better.

One. Cookies

This website uses two types of cookies: session cookies and persistent cookies. Session cookies are stored in the cookies folder of the browser during your visit to the website, while persistent cookies are stored in the browser for a longer period of time (the specific time depends on the life cycle of the cookies folder). Most browsers allow visitors to accept or decline cookies, or notify visitors every time it sends cookies. You can choose to accept or decline cookies by adjusting your browser settings. However, for the website of Shandong Airlines and other large websites using cookies, this may limit the visitor’s use of special functions of the website.

Two. Web beacons

When a user opens a webpage containing web beacons, web beacons and cookies will together record simple operations of the user. When a user’s browser requests information from a certain website in this way, simple information will also be collected, including: the IP address of your computer, the time and content of web browsing, the type of server used, the cookies set by the server earlier, etc. All web servers you accessed can obtain such information. Web beacons will not leak any “extra” information. They are just a convenient way to collect the simplest statistical data and manage cookies. Web beacons can be disabled (in the same way of disabling cookies).

Three. Our SDK provider

In order to guarantee the steady operation of APP or the realization of relevant functions, we may access SKDs provided by third parties. We will exercise the duty of prudence, carry out rigorous security check of the information-obtaining SDKs of our cooperation partners, and request third-party service vendors to take strict data protection measures, so as to effectively safeguard your lawful rights and interests.

The third-party SDKs we accessed mainly serve the needs of you and other users. Therefore, when meeting new service demands and changing business functions, we may adjust the third-party SDKs accessed. We will publicly notify you of the up-to-date state of the third-party SDKs accessed promptly. The information of third-party SDKs accessed by this APP so far is as follows:

Name of SDK

Name of cooperation partner

Usage

Permission   applied for

Alipay SDK

Alipay   (China) Network Technology Co., Ltd.

Order payment

Access to network information

Permission  to read cell phone information

WeChat   SDK

Shenzhen   Tencent Computer Systems Company Limited

Order payment

WeChat   SDK

JPush SDK

Shenzhen   Hexun Huagu Information Technology Co., Ltd.

Push   notification

Access   to network information

Permission   to read cell phone information

Access   to location

Baidu   Maps SDK

Beijing   Baidu Netcom Science and Technology Co., Ltd.

Positioning of departure city

Access   to network information

Permission   to read cell phone information

Access   to location

Dingxiang   Verification Code SDK

Beijing   Dingxiang Technologies Co., Ltd.

Risk control

Access   to network information

Permission   to read cell phone information

Access   to location

Dingxiang   Risk Control SDK

Beijing   Dingxiang Technologies Co., Ltd.

Risk control

Access   to network information

Permission   to read cell phone information

Access   to location

Tingyun   SDK

Beijing   Networkbench Co., Ltd.

Data statistics and network detection

Access   to network information

Permission   to read cell phone information

Access   to location

Gridsum   SDK

Beijing Gridsum Technology   Co., Ltd.

Data statistics

Access   to network information

Permission   to read cell phone information

Access   to location

UnionPay   SDK

China   UnionPay Co., Ltd.

Order payment

Access   to network information

Permission   to read cell phone information

LianLianPay   SDK

Lianlian   Yintong Electronic Payment Co., Ltd.


Access   to network information

Permission   to read cell phone information

ABC   Pay SDK

Agricultural   Bank of China Limited

Order   payment

Access   to network information

Permission   to read cell phone information

Liveness   Detection SDK

Beijing   Linkface Technology Co., Ltd.

Collection   of live face images

Access   to camera

ID   Photo OCR SDK

Beijing   Linkface Technology Co., Ltd.

Collection   of certificate and bank card images

Access   to camera

Permission   for storage

TravelX   SDK

Portus   (Beijing) Technology Co., Ltd.

Data   statistics and marketing promotion

Access   to network information

Permission   to read cell phone information

ek   Co., Ltd.SDK

iFlytek   Co., Ltd.

Flight   information inquiry with voice input

Access   to network information

Permission   to read cell phone information

Access   to microphone

Talk99   SDK

Duoyou   Technology (Beijing) Limited Company

Online   customer service

Access   to network information

Permission   to read cell phone information

Access   to camera

Permission   for storage

III. How we share, transfer and publicly disclose your personal information

One. Sharing

We will only share your personal data for lawful, legitimate, necessary, honest, specific and explicit purposes, and we will only share necessary personal data for providing services. Your personal data will be processed by the subject officially designated in advance as the data processor or data controller for the above-mentioned purposes only. We will use commercially reasonable efforts to carry out an audit of the data security capacity of third parties with which your personal data is shared, sign a non-disclosure agreement with them, and request them to process your personal data in accordance with this Privacy Policy and other relevant confidentiality and security measures.

1. Sharing with explicit consent: after obtaining your explicit consent, we will share your personal information with other parties. If required by law, we will notify you in advance to obtain your explicit consent before sharing sensitive information.

2. Sharing under legal circumstances: we may share your personal information in accordance with laws and regulations, litigation and dispute resolution requirements, or the requirements of administrative and judicial organs.

3. How your personal data is transmitted worldwide

Personal data collected and generated during our operations in China will be stored in China, except in the following cases:

(1) Where laws and regulations provide otherwise;

(2) We have notified you and obtained your separate consent;

(3)You take the initiative to conduct individual behaviors including cross-border reservation, booking and transactions.

Based on the purposes specified in this Privacy Policy, your personal information may be transmitted to countries or regions other than your habitual residence for processing, and we will protection your personal information security in accordance with the stipulations of applicable laws.

4. We may share your personal information with our related parties. But we will only share necessary personal information, and we are bound by the purposes specified in this Privacy Policy. If our related parties intend to change the purpose of personal information processing, we will request your consent to authorization again.

5. Sharing with authorized partners. For the purposes specified in this Privacy Policy only, some of our services will be provided jointly by us and our authorized partners. We may share certain personal information with our partners to provide better customer services and user experience. For example, to realize our pick-up and drop-off service, we must share your personal information with our service provider to send a car, or arrange for a partner to provide the service. We will only share your personal data for lawful, legitimate, necessary, specific and explicit purposes, and we will only share necessary personal data for providing services. Our cooperation partners have no right to use the shared personal information for other purposes that are unrelated to our products or services.

At present, our authorized partners include the following:

All companies within Shandong Airlines Group;

China National Aviation Holding Corporation Limited and its subsidiaries;

Air China Limited and its subsidiaries

Guizhou ChinaDataPay Network Technology Co., Ltd.

Shenzhen Hexun Huagu Information Technology Co., Ltd.

Beijing Dingxiang Technologies Co., Ltd.

Beijing Networkbench Co., Ltd.

Beijing Gridsum Technology Co., Ltd.

Beijing Linkface Technology Co., Ltd.

Portus (Beijing) Technology Co., Ltd.

iFlytek Co., Ltd.

Qingdao Chengweixin Zhengxin Co., Ltd.

BOOKING.COM B.V.

Hefei United Rio Sky Electronic Commerce Co., Ltd.

Suppliers, service providers and IT vendors providing operation, promotion and research services for Shandong Airlines;

Other business partners, including air carriers, land transport operators, hotel service providers, frequent flyer program and non-aviation cooperation partners.

The support includes provision of technical infrastructure services, customer services, convenience of payment, mileage accrual and redemption, mail sending, and invoice mailing. We will sign strict non-disclosure agreement with companies, organizations and individuals with which your personal data is shared, and request them to process your personal data in accordance with our instructions, this Privacy Policy and other relevant confidentiality and security measures.

Besides, please note that the third party may have its own privacy policy to explain its collection and use of your personal information, and such privacy policy does not constitute a part of this Privacy Policy. Please read carefully before you decide to consent to its privacy policy.

Two. Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

1. Transfer with explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties. If required by law, we will notify you in advance to obtain your explicit consent before sharing sensitive information.

2. When your personal information needs to be transferred due to merger, division, dissolution or declared bankruptcy of service providers, we will notify you of the name and contact method of the receiving party, and request the new company, organization or individual holding your personal information to be bound by this Policy. If the receiving party intends to change the purpose and method of processing, we will request such company, organization or individual to ask you for consent to authorization again.

Three. Public disclosure

We will only publicly disclose your personal information under the following circumstances:

1. We may publicly disclose your personal information with your separate consent;

2. When it is required by laws and stipulations, mandatory administrative enforcement of law or judicial processes to provide your personal information, we may publicly disclose your personal information in accordance with the required type of personal information and method of disclosure. Under the premise of complying with laws and regulations, upon receipt of the above-mentioned requirement for information disclosure, we will request issuance of the corresponding legal document, such as subpoena and investigation letter. We firmly believe that the requests for information should remain as transparent as possible to the extent permitted by law. We have prudently reviewed all requests to ensure that they are legally valid and confined to the data that law enforcement agencies have the legal rights to obtain for specific purpose of investigation.

IV. How we protect and save your personal information

One. Technologies and measures for protecting your personal information

We take personal information security seriously, and we will take all reasonable and feasible security control measures to protect your personal information security:

(1) Develop internal management systems and operation specifications;

(2) Conduct classified management of personal information;

(3)Adopt corresponding technical safety measures including encryption and de-identification.

We have adopted safety protection measures meeting the industry standard to protect the personal information you provided, and prevent data from unauthorized access, public disclosure, use, revision, damage or loss. We will adopt all reasonable and feasible measures to protect your personal information. For example, we use TLS protocol encryption technology to ensure safety during the transport of transactions; targeting the storage of personal information data, we adopt the industry conventional strong encryption technology for encrypted storage of user’s personal information; and we isolate data with isolation technology. All of our accesses to stored data will be recorded and saved by relevant logs, with centralized log collection and integrity monitoring to ensure that log files are not falsified; meanwhile, we will carry out internal and external security scanning and penetration test periodically to ensure the security of production system.

(4)Reasonably determine the operating permission for personal information handling, and carry out regular safety education and training for practitioners;

(5)Develop and organize the implementation of personal information security incident contingence plans.

To cope with possible risks of personal information leakage, damage and loss, we have developed emergency handling measures for personal information leakage, with classification and grading standards for information leakage as well as event reporting and corresponding handling processes established. In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, handling measures we have taken or will take, advice on self-prevention and reduction of risks, remedial measures for you, etc. We will promptly inform you about the incident by email, letter, telephone or push notification. If it is difficult to inform the subject of personal information one by one, we will adopt a reasonable and effective method to publish an announcement. If you find your personal information is leaked, please contact us immediately, so that we can take the corresponding measures.

 (6) Take the initiative to report the handling of persona information security incident according to the requirements of regulatory authorities.

 (7) Meanwhile, we remind you to take reasonable measures to protect your own personal information security, including but not limited to using complex password, changing password regularly, and not disclosing your Shandong Airlines account password and relevant personal information to others.

Two. Time limitation for preservation and storage of your personal information

We will adopt all reasonable and feasible measures to guarantee that irrelevant personal information is not collected. We will only retain your personal information within a period of time necessary for achieving the purposes specified in this Policy, unless it is required or permitted by law to extend the retention period.

We will store your personal information for the minimum period necessary for achieving the purposes specified in this Policy, unless laws and regulations provide otherwise, e.g., the E-Commerce Law requires that we store your transaction order information for no less than three years. After you close your account, we will also delete your stored personal information from this application. Upon reaching the minimum period necessary for achieving the purposes specified in this Policy, we will delete your stored personal information from this application.

If we stop our services or operations, we will notify you at least thirty days in advance, and delete your stored personal information from this application after stopping our services or operations.

V. Information protection for minors under the age of 14

We take the protection of personal information of minors seriously. If you are a minor under the age of 14, you should obtain your parent’s or legal guardian’s consent before using our website/mobile client end/products/services. Regarding the collection of minors’ personal information with the parent’s or legal guardian’s consent, we will only use or disclose such information with the parent’s or legal guardian’s explicit consent or when it’s necessary for the protection of minors.

Considering that it is impossible to tell the age of web visitors, if a minor has provided his/her personal data to us without the parent’s or legal guardian’s consent, his/her parent or legal guardian can contact us to delete such information or cancel the reservation for promotional activities.

For details of children’s personal information protection, please refer to the Shandong Airlines Rules for Children’s Personal Information Protection and Notice to Guardians.

VI. Your Rights

Shandong Airlines takes your concerns about personal information seriously, and protects your rights to access, correct and delete your personal information and withdraw consent with our best efforts, so that you are fully capable of guaranteeing your privacy and security. Your rights include:

One. Access and correct your personal information

Except as provided by laws and regulations, you are entitled to access and correct your personal information any time. Specifically, it includes:

1. Your account information

Website account information: after user login, you can view or revise your personal information in My Profile, including: name, gender, contact number, mobile phone number, date of birth, ID type, ID number, Phoenix Miles card number, address, zip code, email, login password, and membership binding; manage, add and delete frequent passenger information; and view voucher and ticket order information in your account.

APP: by clicking your profile picture in “my profile” in the profile menu in the top-right corner of the home page, you can view all of your personal information submitted to Shandong Airlines, and you can update your personal information in the above method or through customer service hotline 95369.  You can also visit “frequent passenger” and “frequent mailing address” to add, revise or delete your general information (including passenger’s name, ID information, itinerary mailing address, etc.).

Frequent flyer membership information: you can log on the “Phoenix Miles” website to view all of your personal information through “my account—account management.” You can also update your personal information other than card number, name, gender, nationality, date of birth and ID number in your member account, change your password, and add, revise or detect your assignee information, contact information, recipient information, etc. in the above method. If you want to revise your name, gender, nationality, date of birth or ID number, you can call the telephone service center for “Phoenix Miles” members at 95583.

Mileage information: you can check your mileage overview, mileage accrual, etc. in “my account—mileage statement” on the “Phoenix Miles” website, or check your mileage information in the “Phoenix Miles” module of the APP or the “Phoenix Miles member services” module of the Shandong Airlines applet.

If you find errors in our progressing of your personal information, you are entitled to request us to correct or supplement your personal information. You can apply to us for correction or supplementation.

2. Your order information

Website: If you are a registered user of the official website of Shandong Airlines, you can log on the website to check details of your ticket order, pick-up/drop-off order and prepaid luggage order, your order status, and cancel your order on the “my order” page. If your reservation is made as a non-registered user, you can check your ticket order through booking management in navigation bar—itinerary management—non-registered user order

APP: You can view all your ticket orders, service orders and refund history on the “my order” page by clicking the profile picture in the top-right corner of the home page and then “my order.”

Shandong Airlines applet: You can view all your ticket orders and refund history on the “my order” page by clicking the profile picture in the top-right corner of the home page and then “my order.”

3. Your browse information

You can clear your browsing history through your browser.

4. If you need to access or correct other information generated during your use of our products and/or services, please feel free to contact us. We will respond to your request according to the methods and time limit specified in this Privacy Policy.

5. Personal information that you are not allowed to access or correct: except for the above-mentioned information, we cannot allow you to access or correct some of your personal information, which mainly includes your equipment information and your personal information provided for reservation of additional services collected to improve your user experience and guarantee transaction security. We will use the above information within the scope of your authorization. You cannot access or correct such information, but you can contact us to delete data stored in this application.

If you cannot access such personal information through the above link, you can call our customer service at 95369 to demand our response to your access request.

Two. Delete your personal information

Information that you can directly remove or delete on our product and/or service page

You may request us to delete your personal information under the following circumstances:

1. Our processing of personal information violates laws and regulations;

2. We collect or use your personal information without your consent;

3. A minor has provided us with his/her personal data without the parent’s guardian’s consent;

4. Our processing of personal information violates our agreement with you;

5. You have canceled your Shandong Airlines account;

6. We have stopped services and operations.

If we decide to respond to your deletion request, we shall also notify the entities that have received your personal information from us to delete such information promptly, unless laws and regulations provide otherwise, or such entities have obtained your authorization separately. When you delete information in our services/applications, we may not delete the corresponding information from our backup system immediately, but we will delete such information during backup update.

Three. Change the scope of your authorization or withdraw your consent

Regarding the personal information we obtained with your consent, you are entitled to change the scope of authorization for our continuous collection of personal information or withdraw your consent by deleting information, or switching off equipment function, changing privacy settings, canceling identity authentication, etc. You can also withdraw all authorization for our continuous collection of your personal information through account cancellation.

Please understand that we need your personal information to provide you with various services. After you withdraw consent or authorization, we will no longer be able to provide the corresponding service, or process your corresponding personal information. However, your decision to withdraw consent or authorization will not affect our previous processing of your personal information based on your authorization.

Four. Cancel your account

To cancel your member account of our official website, you can call our service hotline at 95369 to apply for account cancelation.

To cancel your “Zhang Shang Fei” member account, you can directly apply for account cancelation on the mobile APP. After your account cancelation, we will stop providing our products and/or services to you upon completion of processing, and delete your personal information stored in this application according to your requirements, unless laws and regulations provide otherwise. Your application for cancelation will be processed in 15 workdays.

To cancel your “Phoenix Miles” member account, you can log on the “Phoenix Miles” website and apply for account cancelation in “my account/account management/permanent account cancelation.” Your application for cancelation will be processed in 30 workdays

Five. If you no longer want to receive promotional information from us, you can unsubscribe in the following method:

1. How to unsubscribe

APP: You can choose whether to receive push notification of our promotional information in your phone’s settings— “app notifications.”

Text message: If you no longer want to receive promotional information from us, you can reply “TD” to unsubscribe.

Email: The emails we sent to you may contain links to our website. If you no longer want to receive promotional information from us, you can click the “unsubscribe” link at the end of an email.

2. For the protection of your privacy, we will not send you any promotional or commodity information involving any sensitive content including religious belief, sex and illness in any method or channel.

3. For security purposes, you may need to provide a written request, or otherwise prove your identity. We may request you to verify your identity first before processing your request. You will be replied within 30 days. In principle, there is no charge for your reasonable requests, but we may charge you a certain cost at our discretion for multiple repeated requests beyond reasonable limits. And we may decline requests that are repeated for no reason, require excessive technical means (e.g., require to develop a new system or change the existing practice fundamentally), jeopardize the lawful rights and interests of others, or are highly unrealistic.

According to the requirements of laws and regulations, we may not respond to your requests under the following circumstances:

(1) Directly related to national security or national defense security;

(2)Directly related to public safety, public health or major public interests

(3) Directly related to criminal investigation, prosecution, trial or execution of judgment;

(4)Sufficient evidence shows your subjective maliciousness or abuse of rights;

(5) Response to your request will result in serious damage to the lawful rights and interest of you or other individuals and organizations;

(6) Involving trade secrets.

Six. Exercise your rights

You are entitled to limit our processing of your personal information, decline our request to use your personal information for automated decision making and portrayal, decline our request to process your publicized personal, or, when required by applicable law, decline our request to share your personal information with any third party.

You can demand to exercise your right by phone or email. Please note that upon your excision of this right, we will stop the processing of your information and wait for your further request, such as correction or deletion of your information.

In order to guarantee your information security, you may need to provide a written request or verify your identity. We will respond to your request for exercising your right within a reasonable period of time permitted by law, and your request will be replied in 10 workdays. Besides, if you are exercising a right on behalf of another person, or request us to check, copy, correct or delete relevant information of the deceased that is stored in this application as a close relative, please provide proof of identity of you or the person, or proof of your relationship with the deceased, such as special power of attorney or certification of death (death) of the deceased.

VII. How we update this Policy

This Privacy Policy may change.

Without your explicit consent, we will not reduce the rights you are entitled to according to this Privacy Policy. Any changes to this Policy will be announced on this page.

Regarding material changes, we will offer more prominent notices (for certain services, we will send notifications by email to explain the specific content of changes to the Privacy Policy).

For the purpose of this Policy, material changes include but are not limited to:

1. Material changes to our service pattern, including purpose of processing personal information, type of processed personal information, and usage of personal information.

2. Material changes to our ownership structure and organizational structure, such as change of ownership due to business adjustment, bankruptcy, mergers and acquisitions, etc.

3. Changes to the primary objects of sharing, transfer, or public disclosure of personal information.

3. Material changes to your rights in personal information handling and the way of exercise.

5. Personal information security impact evaluation report indicates high risks.

VIII. How to contact us

If you want to learn more about any matters in this Privacy Policy or have any questions concerning our handling of your personal information, please contact us by calling the customer service hotline of Shandong Airlines at 95369 or sending an email to b2czb@sda.cn.