Last updated: [May 21, 2025]

Shandong Airlines Co., Ltd. (hereinafter referred to as "we") fully recognizes the importance of personal privacy. In accordance with applicable laws and regulations, we are committed to implementing appropriate security measures to ensure that your personal information remains secure and within your control. Through this Privacy Policy, we aim to explain how we collect, use, store, share, and transfer your information when you use our products and/or services, as well as the means by which you may access, update, delete, and safeguard your information.

This Privacy Policy will help you understand the following:

1. How we collect and use your personal information

2. How we use Cookies and similar technologies

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

4. How we protect and store your personal information

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

6. Your rights

7. Updates to this Privacy Policy

8. How to contact us

This Privacy Policy applies to the products and services provided by Shandong Airlines, including seat reservations, ticket purchases, passenger and baggage transportation, insurance and other ancillary services, as well as the PhoenixMiles frequent flyer program. Please note that this Policy does not apply to services provided to you by third parties.

Before using any of Shandong Airlines' products or services, we strongly encourage you to read and fully understand this Privacy Policy. By using our products or services, you acknowledge that you have understood and agreed to the terms of this Policy. If you have any questions, comments, or suggestions regarding this Policy, you may contact us by calling our customer service hotline at 95369-8 or by emailing us at b2czb@sda.cn.

I. How we collect and use your personal information

(I) We may request that you voluntarily provide your personal information for the following purposes:

1. To fulfill your air transportation contract with us:

(1) Provide you with seat reservation and ticket purchase services

In order to successfully process your flight reservation and ensure your lawful travel, we will need the following information: Passenger's name, gender, date of birth, valid identification document, nationality, country of issuance, document validity period, travel date, contact person's name, mobile phone number, and email address.

To complete the payment process, you may be required to provide the following payment details: Bank card number, expiration date, CVV code, cardholder name, bank reserved mobile phone number, valid ID information, financial account details, and mileage payment password. Please note that we will share your order number, transaction amount, and transaction details required by your chosen payment processor with the respective payment institution. After your ticket purchase is completed, we will generate your order information. The flight ticket order details will include your booking record, ticket number, flight number, departure city, destination, flight time, and class of service.

If you wish to receive a printed itinerary, you will need to provide the recipient's name, mobile phone number, and mailing address. If you request an electronic invoice, you will need to provide the ticket number or valid identification information, name, mobile phone number, or email address. If you need to add an invoice title, you will also need to provide the company name and taxpayer identification number.

(2) Registering and using Shandong Airlines official website membership services

When using the membership services we provide, you will need to provide your name, nationality, identification number, gender, date of birth, mobile phone number, email address, and membership password to register and log in to the membership account.

When you add frequent traveler information to facilitate faster bookings, you will be required to provide details such as the traveler's name, mobile phone number, valid identification document, nationality, country of issuance, and document validity period.

(3) Registering and using PhoenixMiles membership services

If you choose to register as a PhoenixMiles member, you will need to provide your name, contact number, valid identification information, country/region of residence, date of birth, and password. We will then provide you with a PhoenixMiles membership number and your membership tier. When you use your PhoenixMiles membership, your mileage accumulation and redemption information will be generated, including your PhoenixMiles E-shop order records. Your membership tier may also change in accordance with the membership tier rules.

In certain procedures, you are required to provide additional information so we can process your registration and subsequent steps, such as facial recognition. We may collect your facial image, facial recognition feature data, valid identification information, and your PhoenixMiles membership number. If you are a Phoenix Junior member or a VIP member, and we need to collect your mailing address to mail your membership card. If you are a minor under the age of 14, you will need to provide your guardian's associated membership number. You may also voluntarily provide other information, such as your email address, interests, and preferences. To save you the trouble of entering data, we may directly extract certain information from your application form or during the processing stage, including your registration date, registration channel, preferred communication language, and membership brand. You may use your mileage to redeem award tickets for yourself and your transferees, in which case you will need to provide the information required for seat reservation and ticketing services.

You can also use your mileage to redeem products in the PhoenixMiles E-shop or at offline partner locations, in which case you will need to provide the recipient's name, contact number, and mailing address. You may also voluntarily provide frequently used contact and recipient information. We will share your recipient details with the mall vendors and logistics service providers. If the recipient cannot be reached, we may provide your contact information to the vendor. When redeeming products with mileage at offline partner locations, we will share your order details and membership number with the partner service providers. If customer service issues need to be handled by the partner, we may also provide your contact information to them.

If you participate in member-exclusive products, events, or use the mileage payment function (both online and offline), as well as mileage rewards or benefits offered by our business partners, you will be deemed to have consented to our collection and use of your name, identification details, contact number, email address, travel information, and membership information for activity tracking and member service provision.

(4) To provide you with real-name authentication services

If you use our real-name authentication services, you will be required to provide your facial information, bank card information, mobile phone number, name, and ID number. For details regarding the collection and consent of biometric data, please refer to the Facial Information Usage Authorization Letter. Your facial and bank card information will be used solely for that specific verification and will not be stored by Shandong Airlines.

(5) Other services provided to you

If you need to purchase our prepaid baggage, check in a boarding pass, use the irregular flight service and ticket verification services, you will be required to provide your ticket number or valid identification information, name, mobile phone number, flight number and flight date, etc. To use the irregular flight refund service, you will also need to provide the passenger's personal card number.

If you book a hotel, we will also need you to provide the name of the guests, mobile phone number, identification number, check-in and check-out dates, etc.

If you book an insurance product, we will require the departure date, return date, insurance period, policyholder's name, policyholder's date of birth, policyholder's identification number, and policyholder's mobile phone number.

If you book domestic travel services, you will need to provide the traveler's name, mobile phone number, identification number, travel dates, contact person's name, valid identification, and contact person's mobile phone number. If you book an international tour, you will need to provide the traveler's name (in both Chinese and English), gender, nationality, passport number and expiration date, date of birth, photo of the identification document, travel dates, contact person's name and valid identification, contact person's mobile phone number, and contact person's email address.

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

If you choose to participate in our VIP passenger preference survey, you will be required to provide your phone number, identification number, and name for identity verification purposes.

(6) Telephone service provided to you

Our telephone customer service and after-sales functions will use your account information and order information. To ensure the security of your account, our call center and online customer service will use your account information to verify your identity with you. When you need us to provide customer service and after-sales service related to your order information, we will query your order information. To facilitate communication with you and promptly assist in resolving issues or recording the related solutions and outcomes, we may store your communication, correspondence/call records, and related content (including account information, order information, any additional information you provide to support relevant facts, or contact information you leave behind). If you inquire, file a complaint, or provide suggestions regarding a specific order, we will use your account information and order details. You may provide additional information beyond the above-mentioned details when communicating with our customer service staff, such as when requesting changes to your delivery address, contact person, or mobile phone number.

If you need to apply for services such as stretchers, wheelchairs, unaccompanied minors, carrying portable oxygen equipment or ventilator equipment, transporting donated human organs, etc., you need to fill in your name, contact information, valid ID information, and the contact information and address of relevant accompanying persons or airport pick-up and drop-off persons. We will verify your medical certificate or collect relevant supporting documents in accordance with relevant national requirements.

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

(7) Necessary to ensure transaction security

To enhance the security of our systems when you use our products and/or services, and to more accurately prevent phishing fraud and protect account security, we may assess the security risks of your account/transaction by collecting information such as your browsing data, order information, and device information (IP address, device model, device ID, Android ID, OAID, IMEI, IMSI, carrier information, and application list) to identify and prevent fraud.

We also collect your device information (such as IP address, device model, device identifier, Android ID, OAID, IMEI, IMSI, carrier information, and application list) to analyze issues within the Shandong Airlines system, monitor traffic statistics, identify potential risks, and investigate anomalies when you choose to report them to us.

In addition, when you modify key personal information or initiate real-name authentication, you may be required to verify your identity through mobile carrier authentication, facial recognition, or bank card verification. Your name, ID number, phone number, and bank card information will be shared with telecom carriers and China UnionPay to confirm your membership identity and ensure the security of your account. Mobile carrier authentication is technically supported by Chongqing Wangdian Technology Co., Ltd. and Qingdao Chengweixin Credit Information Co., Ltd., while bank card authentication is technically supported by Chongqing Wangdian Technology Co., Ltd.

(II) Situations where you may choose whether to authorize us to collect and use your personal information

To enhance your service experience, the following optional features may involve the collection and use of your personal information.

If you choose not to provide this information, you can still use basic functions such as seat reservations and ticket purchases, though you may need to re-enter some details. These optional features include:

1. Location-based personalized recommendation: Accessing your approximate or precise location to determine your current airport.

2. Camera-based features: We access your camera to allow scanning QR codes, taking photos for real-name and facial authentication, participating in promotional activities, uploading custom avatars, or submitting refund-related documents.

3. Image upload-based features: Accessing your photo album enables you to retrieve and upload photos, images, or videos from your device, facilitating avatar changes or providing proof to online customer service when reporting issues.

4. Voice technology-based features: We access your microphone to enable voice-based flight inquiries.

5. Contacts-based features: We access your address book to make it easier for you to retrieve contact information when booking tickets, eliminating the need to manually input contact details saved in your device.

6. Phone call convenience service: We request permission to make phone calls so you can directly dial our customer service hotline without manually entering the number.

To enable the above features, you may need to grant access on your device to your location, camera, photo album, microphone, contacts, and phone call functionality. These permissions allow us to collect and use the relevant information necessary for these optional services.

You have full control over whether to enable or disable these permissions at any time (we will guide you through the settings in your device's system). For example, you can manage the use of facial recognition by toggling its switch. If you choose to proceed with identity authentication and related services, you may voluntarily consent to or cancel the authentication process.

Please ensure that you have obtained full authorization from any third party before providing their personal or sensitive information via these features. It is your responsibility to ensure that your actions do not infringe upon the legal rights of any third party and that such third parties can process their data in accordance with this Privacy Policy. If a third party requests the deletion or correction of related information, you are required to promptly fulfill that request; otherwise, you may bear legal consequences resulting from inaction. If we change the purpose of using third-party information due to business needs, we will promptly inform you, so you can decide—based on the third party's authorization—whether the data may continue to be processed.

In addition, when you follow our official WeChat account, official Weibo account, or other social media accounts, your voluntary action to follow us will be deemed as valid consent. We may identify specific follower information and the time of follow, but this information will only be used to interact with you on the platform. You may withdraw your consent at any time by unfollowing the account.

(III) Personal information we may collect indirectly

To better perform identity verification, ensure transaction security, and provide after-sales services, we may obtain your personal information from third parties (for example, when you book tickets through our official stores or agents on third-party platforms). If your personal information is indirectly obtained by our company from a third-party source, we will use it only after confirming the legitimacy of the information source in accordance with our agreement with the third party, and under the premise of complying with applicable laws and regulations.

(IV) Information we collect automatically

When you access our App, we automatically collect certain information from your device due to technical and device-related reasons. The information we collect automatically includes:

Device information, such as device model, operating system version, browser version, IMEI number, IMSI number, Android ID, OAID, MAC address, IP address, port information, DNS, mobile carrier, data network type, ROOT status, network access method, login channel, APP version, login time, hardware identifier, and other log and technical parameter information related to your network, system, and device.

Please understand that this information is essential for third-party services such as Aurora and Alipay to analyze and determine device uniqueness and conduct security risk control. We use this information for operational purposes, helping us better understand our user base and improve the quality and relevance of our website. If you refuse the collection of such information, we will be unable to provide you with basic functions or services within the App.

(V) Exceptions to obtaining authorized consent

According to relevant laws and regulations, we are not required to obtain your consent when collecting your personal information under the following circumstances:

1. When it is necessary to sign or perform a contract at your request;

2. When it is required to fulfill legal duties or obligations;

3. When it is necessary to respond to public health emergencies, or to protect the life, health, and property safety of individuals in an emergency;

4. When personal information is processed within a reasonable scope for news reporting, public opinion monitoring, or other activities in the public interest;

5. When personal information is processed within a reasonable scope in accordance with this law from information that you have disclosed yourself or that has been otherwise legally disclosed;

6. Other circumstances as stipulated by laws and administrative regulations.

If we cease operation of Shandong Airlines' products or services, we will promptly stop collecting your personal information, notify you of the service termination either individually or through public announcements, and delete any personal information we hold within this application.

(VI) List of device permissions we may request

We may request access to certain permissions on your device along with corresponding explanations, and will obtain your consent before doing so. You may revoke these permissions at any time through your device's system settings. The permissions we may request and their intended purposes include:

(1) Contacts Permission: It is used to conveniently access your contact information during ticket booking, and eliminate the need to manually enter contact names and phone numbers, and to notify you of ticket issuance details;

(2) Phone Status Permission: We may collect your device's unique identifiers such as IMEI, IDFA, MAC address, Android ID, and Device_ID. This information is essential for implementing security measures, including network and payment security risk control, and may be used to push service notifications to your app. This is a fundamental permission required to provide you with services;

(3) Storage Permission: Our App needs access to file storage on your device to cache data such as airport information and read image files. Therefore, we require access to your device's file storage permission, which is a fundamental permission necessary to provide our services;

(4) Network Permission: Access to network (including mobile data or Wi-Fi) is required for online ticketing, check-in, and related services;

(5) Microphone Permission: Access to your microphone is needed to recognize your voice input for flight inquiries. If you deny this permission, it will only affect the specific voice-related features but will not impact your use of other functions;

(6) Access to Installed App List: We may need permission to read your list of installed applications in order to determine whether our App is running in the foreground or background. If you deny this permission, it will only affect related features but not other functionalities;

(7) Camera Permission: Required for taking photos and for document recognition features;

(8) Call Permission: Allows the app to initiate phone calls to customer service;

(9) Location Permission: Used to display your current city in the city list, which supports services such as flight inquiries and airport transfers;

(10) Notification Permission: Allows you to receive system notifications such as flight updates and promotional offers by enabling push notifications;

(VII) Situations where we obtain your personal information from third parties

To better perform identity verification, ensure transaction security, and provide after-sales services, we may obtain your authorized shared personal information from third parties. If your personal information is indirectly obtained by our company from a third-party source, we will use it only after confirming the legitimacy of the information source in accordance with our agreement with the third party and in compliance with relevant laws and regulations.

For example, you may book flight tickets through Shandong Airlines' official store or an online agent on a third-party platform. After confirming the legitimacy of the information source and based on our agreement with the third party, we will use your personal information in accordance with relevant laws and regulations.

In addition, please note that third parties may have their own dedicated privacy policies outlining how they collect and handle your personal information. These privacy policies are not part of this Privacy Policy, and we advise you to read them carefully and make your own decision on whether to agree to their terms.

(VIII) Rules for the use of your personal information

We use the personal information we collect in accordance with this Privacy Policy and for the purpose of delivering our products and/or services. Please note that all personal information you provide while using our products and/or services, or any sensitive personal information collected based on your explicit consent, will continue to be used during the period in which you use our products and/or services—unless you delete the information, withdraw your consent, or disable our access through system settings. Once you withdraw your consent or cancel your account, we will stop using and delete your personal information stored within the application.

(IX) About third-party links

Our company's website may contain links to websites owned and/or operated by third parties. We do not have control over, and are not responsible for, the content or privacy practices of such websites. We recommend that you carefully review the applicable privacy policies before using those third-party websites or providing any personal information to them.

II. How we use Cookies and similar technologies

When you use our website, we may collect tracking information such as your browser type, operating system, internet service provider, and the web pages you visit on our site. Shandong Airlines uses various technologies to gather this information, including Cookies and Webbeacons, to enhance the functionality and usability of our website, and to ensure our site, products, and services better meet your needs. In addition, we use this information to determine whether visitors are eligible to submit service requests and to compile aggregated data on website activity.

(I) Cookies

This website uses two types of cookies: session cookies, which are stored in your browser's cookie folder during your visit and are deleted once you close the browser; and persistent cookies, which remain in your browser for a longer period (depending on the cookie's lifespan). Most browsers allow users to control whether to accept cookies, reject them, or be notified each time a cookie is sent. You may choose to reject cookies by adjusting your browser settings; however, doing so may limit your ability to use certain features of the Shandong Airlines website and other websites that rely on cookies.

(II) Web Beacons

When users open a webpage containing web beacons, the web beacon works in conjunction with cookies to record simple user actions. When your browser requests information from a website in this way, it may also collect some basic information, such as your computer's IP address, the time and content of the pages you visit, the type of browser you use, and any cookies set previously by that server. Any web server you visit can collect such information. Web beacons do not disclose any "extra" information. They are simply a convenient way to collect basic statistical data and manage cookies. Web beacons can be disabled (the same way you disable cookies).

(III) Our SDK providers

To ensure the stable operation of our App or to implement related features, we may integrate third-party software development kits (SDKs) for these purposes. We will exercise due diligence by performing rigorous security checks on the SDKs provided by our partners and require third-party service providers to implement strict data protection measures to safeguard your legal rights.

The third-party SDKs we integrate primarily serve you and other users' needs. Therefore, when new service requirements or business function changes arise, we may adjust the third-party SDKs we use. We will promptly disclose any updates regarding the integration of third-party SDKs in this notice. The third-party SDKs currently integrated into the App are as follows: 

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

(I) Sharing

We may share your personal data for legitimate, lawful, necessary, honest, specific, and clear purposes, and only share the personal data that is necessary to provide services. The personal data will only be processed by entities formally designated as data processors or data controllers in advance, and for the purposes outlined above. For third parties with whom we share personal data, we will make reasonable commercial efforts to audit their data security capabilities, sign confidentiality agreements with them, and require them to handle 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 and obtain your explicit consent before sharing sensitive information.

2. Sharing in statutory circumstances: We may share your personal information externally in accordance with laws and regulations, for dispute resolution in legal proceedings, or as required by administrative or judicial authorities.

3. How your personal information is transmitted globally

Personal information collected and generated within the People's Republic of China will be stored within the People's Republic of China. Except for the following circumstances:

(1) Where otherwise provided by laws and regulations;

(2) When we have informed you and obtained your separate consent;

(3) When you initiate cross-border bookings, orders, transactions, or other personal actions.

Based on the purposes outlined in this Privacy Policy, your personal information may be transferred to and processed in countries or regions outside of your usual place of residence. At this point, we will protect the security of your personal information in accordance with applicable laws and regulations.

4. We may share your personal information with our affiliates. However, we will only share the necessary personal information, and such sharing will be subject to the purposes stated in this Privacy Policy. If our affiliates intend to change the purpose of processing your personal information, they will seek your authorization and consent again.

5. Sharing with authorized partners. Some of our services will be provided by us and authorized partners only for the purposes stated in this Privacy Policy. We may share some of your personal information with partners to provide better customer service and user experience. For example, when you use pick-up and drop-off services, we must share your personal information with the service provider in order to arrange transportation or have a partner to provide the service. We will only share your personal information for legitimate, lawful, necessary, specific, and clear purposes, and will only share the personal information necessary to provide the service. Our partners are not authorized to use the shared personal information for purposes unrelated to the product or service.

Currently, our authorized partners include the following:

Any company within the Shandong Airlines Group;

China TravelSky Holding Company Limited and its subsidiaries;

Air China and its subsidiaries;

Chongqing Wangdian Technology Co., Ltd.

Shenzhen Hexun Huagu Information Technology Co. Ltd.

Beijing Networkbench Co., Ltd.

BOOKING.

Hefei Liantuo.com E-commerce Co., Ltd.

Suppliers, service providers, and IT vendors that provide operations, promotion, and research for Shandong Airlines' business;

Other business partners, such as air carriers, ground transport operators, hotel service providers, frequent flyer programs, and non-airline partners;

These supports include providing technical infrastructure services, customer service, payment facilitation, mileage accumulation and redemption, email delivery, and invoice mailing. For the companies, organizations, and individuals with whom we share personal information, we will enter into strict confidentiality agreements with them, requiring them to process personal information, including sensitive personal information, in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

In addition, please note that third parties may have their own dedicated privacy policies outlining how they collect and handle your personal information. These privacy policies are not part of this Privacy Policy, and we advise you to read them carefully and make your own decision on whether to agree to their terms.

(II) Transfer

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

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 and obtain your explicit consent before transferring sensitive information.

2. If a service provider undergoes a merger, division, dissolution, or is declared bankrupt and requires the transfer of personal information, we will inform you of the name and contact information of the receiving party. We will also require the new company or organization holding your personal information to continue adhering to this Policy. If the receiving party changes the original purpose or method of processing, we will require that company, organization, or individual to seek your authorization and consent again.

(III) Public Disclosure

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

1. With your separate consent, we may publicly disclose your personal information;

2. If required by laws, regulations, mandatory administrative enforcement, or judicial orders to provide your personal information, we may publicly disclose your personal information in accordance with the required types and methods of disclosure. On the premise of complying with laws and regulations, when we receive the above-mentioned request for disclosure of information, we will require that corresponding legal documents such as subpoenas or investigation letters must be issued. We firmly believe that the information we are required to provide should be kept as transparent as possible within the scope allowed by law. We carefully review all requests to ensure they have a legal basis and are limited to data that law enforcement authorities are legally entitled to access for specific investigative purposes.

IV. How we protect and store your personal information

(I) Our technology and measures to protect your personal information

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

(1) Formulate internal management systems and operating procedures;

(2) Implement classified management of personal information;

(3) Take corresponding security technologies such as encryption and de-identification;

We have implemented security measures that meet industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, we use Transport Layer Security (TLS) encryption technology to ensure the security of transactions during transmission; for stored personal data, we apply commonly used strong encryption techniques to encrypt and store user information; and we use isolation technologies for data separation. Access to stored data is logged and recorded, and through centralized log collection and integrity monitoring, we ensure that log files cannot be tampered with. Additionally, we periodically conduct internal and external security scans and penetration tests to ensure the security of our production systems.

(4) Reasonably determine the operational permissions for personal information processing and regularly conduct security education and training for personnel;

(5) Formulate and  implement an emergency plan for personal information security incidents.

To address potential risks such as personal information leakage, damage, or loss, we have established emergency measures for personal information leakage. These measures include classification and grading standards for leakage incidents, as well as procedures for reporting incidents and corresponding response actions. In the unfortunate event of a personal information security incident, we will promptly notify you, in accordance with legal and regulatory requirements, of the following: the basic details of the security incident and its potential impact, the measures we have taken or will take to address the incident, recommendations for actions you can take to prevent or mitigate risks, and any remedial actions we will provide. We will notify you promptly through email, letters, phone calls, push notifications, etc. If it is difficult to notify each individual, we will issue an announcement through reasonable and effective means. If you discover that your personal information has been leaked, please contact us immediately so that we can take the necessary actions.

(6) We will also proactively report the handling of personal information security incidents to the regulatory authorities as required.

(7) At the same time, we remind you to take reasonable measures to protect your personal information security, including but not limited to using complex passwords, regularly changing your passwords, and not sharing your account and password or other personal information with others.

(II) Retention and storage period of your personal information

We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will retain your personal information only for as long as necessary to achieve the purposes outlined in this Policy, unless an extension of the retention period is required or permitted by law.

We will store your personal information for the shortest period necessary to fulfill the purposes described in this Policy, unless otherwise required by applicable laws and regulations, such as the E-Commerce Law of the People's Republic of China, which requires us to store your transaction order information for at least three years. After you cancel your account, we will also delete your personal information stored in the application. When your personal information exceeds the minimum period required to achieve the purposes mentioned above, we will delete your personal information from the application.

If we terminate our services or operations, we will notify you at least thirty days in advance, and after the termination of services or operations, we will delete your personal information stored in the application.

V. Protection of personal information of minors under the age of 14

We take the protection of minors' personal information very seriously. If you are a minor under the age of 14, you must obtain consent from your parents or legal guardians before using our website/mobile app/products/services. In cases where we collect personal information from minors with the consent of their parents or legal guardians, we will only use or disclose this information when permitted by law, with the explicit consent of the guardian, or when necessary to protect the minor.

Considering that we cannot identify the age of online visitors, if a minor provides personal information to our company without the consent of their parent or guardian, the parent or guardian may contact us to delete such information or cancel any promotional activities or offers.

For specific details about children's personal information protection, please refer to the Children's Personal Information Protection Policy and Notice to Guardians of Shandong Airlines.

VI. Your rights

Shandong Airlines values your concern regarding personal information and makes every effort to protect your rights to access, correct, delete, and withdraw consent for your personal information, ensuring that you have full control over safeguarding your privacy and security. Your rights include:

(I) Accessing and correcting your personal information

Except as otherwise stipulated by laws and regulations, you have the right to access and correct your personal information at any time. Specifically, this includes:

1. Your account information:

Website account information: After logging in, you can view or modify your personal information in the "Profile" section, including: name, gender, contact phone number, mobile phone number, date of birth, ID type, ID number, PhoenixMiles card number, address, postal code, email address, login password, and membership binding; you can manage and add/remove frequently used passenger information; you can view voucher information and ticket order details in your account.

APP: You can view all the personal information you have submitted to Shandong Airlines by accessing your profile picture in the "My Profile" section of the menu in the top right corner of the home page. You can also update your personal information through the same section or by contacting customer service at 95369-8. Additionally, you can access "Frequent Flyers" and "Frequent Mailing Addresses" to add, modify, or delete your frequently used information at any time (including passenger names, passenger ID information, itinerary mailing address details, etc.).

Frequent Flyer Membership Information: You can log in to the "PhoenixMiles" website and view all your personal information by going to "My Account - Profile Management." You can also update your personal information, except for the card number, name, gender, nationality, date of birth, and ID number, through the same section. Additionally, you can change your password, and add, modify, or delete your beneficiary information, contact information, and recipient information. If you wish to modify your name, gender, nationality, date of birth, or ID number, you can contact the "PhoenixMiles" Membership Service Center by calling 95583.

Mileage Information: You can check your mileage overview, accumulated mileage, etc., under "My Account - Mileage Statements" on the "PhoenixMiles" website, or you can check mileage information via the "PhoenixMiles" module on the App or the "PhoenixMiles Member Services" module in the Shandong Airlines mini-program.

If you find that the personal information we process about you is incorrect, you have the right to request correction or supplementation. You can submit a request for correction or supplementation to us.

2. Your order information:

Website: If you are a registered user on the Shandong Airlines official website, you can log in and view the details of your ticket orders, airport transfer orders, prepaid baggage orders, order status, and cancel orders through the "My Booking" page. If you booked as a non-registered user, you can view your ticket orders by going to the navigation bar, selecting "Booking Management" > "Manage Itinerary" > "Non-Registered User Booking."

APP: You can view all your ticket orders, service orders, or refund history by accessing the "My Booking" page. The specific path is: Home page > top right corner avatar > "My Booking."

Shandong Airlines Mini-Program: You can view all your ticket orders or refund history by accessing the "My Booking" page. The specific path is: Home page > Me > "My Booking."

3. Your browsing information:

You can clear your history through the browser you use.

4. If you need to access or correct other personal information generated during the use of our products and/or services, please feel free to contact us. We will respond to your requests in accordance with the methods and timeframes outlined in this Privacy Policy.

5. Personal information that you cannot access and correct: Apart from the information mentioned above, there are certain types of personal information that we cannot provide access or correction services for. This mainly includes device information collected to enhance your user experience and ensure transaction security, or personal information you provide when booking additional services. These pieces of information will be used within the scope of your authorization, and while you cannot access or correct them, you can contact us to delete the data stored in this application.

If you are unable to access this personal information through the above link, you can call Shandong Airlines' customer service hotline at 95369-8 to request a response to your access request.

(II) Deleting your personal information

The information that you can directly clear or delete in our products and/or services pages.

You can ask us to delete your personal information in the following circumstances:

1. If our processing of personal information violates laws and regulations;

2. If we collect and use your personal information without obtaining your consent;

3. If a minor provides personal information to the company without the consent of his or her parents or guardians;

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

5. If you have canceled your Shandong Airlines account;

6. If we terminate the service and operation.

If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us and ask them to delete it promptly, unless otherwise required by laws and regulations, or if those entities have obtained your independent authorization. When you delete information from our services/applications, we may not immediately delete the corresponding information from our backup systems, but it will be removed when the backups are updated.

(III) Changing the scope of your authorization or withdrawing your authorization

For personal information we have collected based on your consent, you have the right to change the scope of your authorization or withdraw your authorization through methods such as deleting information, turning off device features, adjusting privacy settings, or canceling identity verification. You can also withdraw all your authorization for us to continue collecting your personal information by canceling your account.

Please understand that Shandong Airlines requires your personal information to carry out its services. If you withdraw your consent or authorization, we will no longer be able to provide the services corresponding to the withdrawn consent or authorization and will cease processing your relevant personal information. However, the decision to withdraw your consent or authorization will not affect the processing of personal information that was carried out based on your consent prior to the withdrawal.

(IV) Canceling account

If you wish to cancel your official website membership account, you can call the 95369-8 customer service hotline to request account cancellation.

If you wish to cancel your "Zhangshangfei" membership account, you can directly apply for account cancellation within the mobile App. After you cancel your account, we will stop providing you with products and/or services after the cancellation process is completed, and according to your request, unless otherwise provided by laws and regulations, we will delete your personal information stored in this application. Your cancellation request will be processed within 15 working days.

If you wish to cancel your "PhoenixMiles" membership account, you can log in to the "PhoenixMiles" website and apply for account cancellation under "My Account/Profile Management/Permanently Cancel Account." Your cancellation request will be processed within 30 days.

(V) If you do not want to receive promotional information from us, you can cancel at any time by the following methods:

1. Cancellation methods

APP: You can go to your phone settings > "App Notifications" to choose whether to accept promotional information from us via push notifications.

SMS: If you no longer wish to receive promotional information from us, you can unsubscribe at any time by replying "TD" to the message.

Email: The emails we send you may contain links to our website. If you do not wish to receive further promotional information from us, you can cancel by clicking the "Unsubscribe" link at the bottom of the email.

2. To protect your privacy, we will not push any promotional or product information related to sensitive content such as religious beliefs, sex, or diseases to you in any way or through any channel.

3. For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. We will respond within thirty days. In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost fee depending on the situation. For requests that are baseless, require excessive technical effort (e.g., requiring the development of new systems or fundamentally changing current practices), pose risks to the legal rights of others, or are unrealistic, we may refuse to process them.

In the following circumstances, we will not be able to respond to your request in accordance with legal and regulatory requirements:

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

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

(3) Directly related to criminal investigations, prosecution, trials, and the enforcement of judgments;

(4) Where there is sufficient evidence to suggest that you have subjective malice or are abusing your rights;

(5) Where responding to your request would cause significant harm to the legal rights of you or others;

(6) Involving trade secrets.

(VI) Exercising your rights

You have the right to limit our processing of your personal information under specific circumstances, refuse our use of your personal information for automated decision-making and profiling, reject our processing of your publicly disclosed personal information, or, where applicable law requires, refuse to share your personal information with third parties.

You can exercise this right by contacting us via phone or email. Please note that once you exercise these rights, we will stop processing your personal information and wait for further instructions from you, such as requests to correct or delete your information.

To ensure the security of your information, we may ask you to provide a written request or verify your identity. Afterward, we will respond to your rights request within a reasonable timeframe allowed by law. We will reply to your request within 10 working days. Furthermore, if you are exercising rights on behalf of someone else, or if you are a close relative of a deceased person and wish to inquire, copy, correct, or delete information about the deceased stored in the application, please provide identification documents for both yourself and the other party, as well as proof of your relationship, such as a special power of attorney or a death (presumed) certificate of the deceased.

VII. Updates to this Privacy Policy

Our Privacy Policy may be updated from time to time.

We will not reduce the rights you are entitled to under this Privacy Policy without your explicit consent. Any changes to this Policy will be posted on this page.

For significant changes, we will provide more prominent notifications (including, for certain services, sending notifications via email to explain the specific changes to the privacy policy).

Major changes referred to in this Policy include, but are not limited to:

1. Significant changes to our service model. Such as changes in the purposes for processing personal information, the types of personal information processed, or how the personal information is used;

2. Significant changes in our ownership structure, organizational structure, etc. Such as ownership changes due to business adjustments, bankruptcy, mergers, and acquisitions;

3. Changes in the main parties with whom personal information is shared, transferred, or publicly disclosed;

4. Significant changes in your rights related to personal information processing and the way those rights can be exercised;

5. When personal information security impact assessments indicate high risks.

VIII. How to contact us

If you would like to contact us regarding any matters related to this Privacy Policy, or if you have any questions about how we process your personal information, you can reach us by calling the Shandong Airlines customer service hotline at 95369-8 or by sending an email to b2czb@sda.cn.