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深セン航空有限責任公司プライバシーに関するお知らせ

Last updated: November 13, 2025

Issued on/effective date: November 13, 2025

Shenzhen Airlines Company Limited (hereinafter referred to as "we," "Shenzhen Airlines," or "the Company") fully understands the importance of protecting passengers' personal information and will take appropriate security measures in accordance with laws and regulations. We hope to use this Privacy Policy to explain to passengers ("you") how we collect and use your personal information when you use our different products and services.

This Privacy Policy will help you understand the following:

1. How Does Shenzhen Airlines Collect and Use Your Personal Information

2. How Does Shenzhen Airlines Use Cookies and Similar Technologies

3. To Whom Does Shenzhen Airlines Share, Transfer, or Disclose Your Personal Information

4. Rules for Shenzhen Airlines in Using Your Personal Information

5. Legal Basis for Shenzhen Airlines to Process Your Personal Information

6. How Does Shenzhen Airlines Protect and Store Your Personal Information

7. Protecting the Personal Information of Minors

8. How Is Your Personal Information Transmitted Globally

9. Your Rights to Personal Information Protection

10. Updates to the Privacy Notice

11. How to Contact Us

Before using any of our products or services, please be sure to read and thoroughly understand this Privacy Policy, and only use the relevant products or services after you have fully understood and accepted it. If minors use our services, please read and understand this Privacy Policy and the Children's Personal Information Protection Rules of Shenzhen Airlines together with your parents or guardians.

According to the Regulations on the Scope of Necessary Personal Information for Common Types of Mobile Internet Applications, the service products provided by Shenzhen Airlines belong to the category of transportation ticketing. The core business function is "transportation-related ticketing services and itinerary management (including flight tickets and service product purchases, ticket changes, refunds, and itinerary management)." The necessary personal information includes:

1. Passenger's mobile phone number;

2. Passenger's name, ID type, ID number, and passenger type. Passenger type generally includes adult, child, and infant;

3. Passenger's departure location, destination (To), departure time, flight number, cabin class, and seat number;

4. Transaction record information, including transaction bank card number, credit card validity period, and CVV2 code, personal information provided by online payment platforms, "Shenzhen Airlines YeePay" information, transaction orders, and operation logs.

I. How Does Shenzhen Airlines Collect and Use Your Personal Information

(I) We will ask you to provide your personal information for the following purposes, and you may provide it on a voluntary basis:

1. The information you provide to us is used:

(1) To provide you with seat reservation and ticketing services

To complete your seat reservation and ticketing services, you need to provide the following information: passenger's name, ID type, ID number (Please note, ID information is considered sensitive personal information in China), passenger type, passenger mobile phone number, frequent flyer program (optional), contact person's name, contact person's phone number, and email address (required when purchasing tickets outside China). If you are purchasing a ticket using an ID type other than an ID card in the Chinese mainland or a resident permit of the Hong Kong (China)/Macao (China)/Taiwan (China) regions, you also need to provide the passenger's name (in pinyin), gender, date of birth, nationality (country/region), ID validity period, and place of issue. To complete your payment, you need to provide the following payment information (Please note, financial account information is considered sensitive personal information in China): bank card number, validity period, CVV2 code, billing address, cardholder name, mobile phone number registered with the bank, ID type, ID number, mileage payment password, Shenzhen Airlines YeePay account information, account personal information provided to us by online payment platforms (Alipay, WeChat), such as your Alipay or WeChat Pay account details, payment results, and transaction records. You need to understand that we need to share your order details, transaction amount, and transaction information required by the chosen payment institution with that payment institution. If you refuse to provide the aforementioned information, you will only be unable to use the corresponding functions, but this will not affect your use of our other products and services. After you complete your ticket purchase, we will generate your order information. The flight order information will include your seat reservation record, ticket number, flight number, departure location (From), destination (To), travel date and time, and cabin class.

If you need to issue an electronic invoice or electronic flight itinerary, you will need to provide your ticket number, name, ID type, ID number, mobile phone number, and dynamic verification code. When adding an invoice header, you will also need to provide the invoice title, taxpayer identification number, and the email address where you wish to receive the invoice.

(2) To provide you with passenger and baggage transportation services

When selecting a seat and checking in, you will need to provide your ticket number or ID number, name, flight number, and flight date. After your seat number is confirmed, a boarding pass will be generated. When you check in at the airport, we will check your ticket number and valid identification. After your seat number is confirmed, your boarding pass will be generated.

If your flight is delayed and you request a delay certificate, we will collect your name, ticket number or ID number, flight number, and your travel date.

To assist you with checked baggage, we will verify your ticket number and generate a baggage number for you.

(3) To help you register and use Shenzhen Airlines account services

When using our Shenzhen Airlines account-related services, you need to provide your name, ID type, ID number, date of birth, mobile phone number and verification code, and email address (optional) for the purpose of registering and logging into your Shenzhen Airlines account. You can modify and supplement your real-name authentication information, all of which is considered your personal information. The personal information you supplement will help us provide you with a better flight experience.

(4) To help you register and use Phoenix Miles membership services

If you choose to register as a Phoenix Miles member, you will need to provide your name (Chinese name, English name/Chinese name in pinyin), ID type, ID number, mobile phone number, email address (optional), nationality (country/region), date of birth, gender, and password. We will then provide you with your Phoenix Miles membership card number and your membership level. When you use your Phoenix Miles membership, information about your mileage accumulation and redemption will be generated, and your membership level may change according to the membership tier rules.

To protect the sensitive personal information of minors under the age of 14, if you are a minor under 14 years old, your guardian is required to fill in the guardian's linked card number to ensure guardian consent.

In addition, you may also voluntarily provide your email address (for receiving service or marketing emails), choose whether to receive promotional information, and whether to receive travel service notifications.

To save you the trouble of entering information, we will directly extract certain information from your application form or during processing, including your registration date, registration channel, preferred communication language, and membership brand. You can use your miles to redeem reward tickets for yourself and your designated transferee, and you will be required to provide the information necessary for seat reservation and ticketing services. As an additional way for members to accumulate miles, we have initially enabled an automatic membership card recognition service for all members. When members purchase tickets for flights operated by Shenzhen Airlines through the China Civil Aviation Information Group Co., Ltd.'s system, if the passenger's name and valid ID number match the information registered in the member account, the membership card number will be automatically recognized and the flights taken may be automatically credited with miles. If you do not want to use the automatic recognition service, you can log in to your Phoenix Miles member account and turn off automatic membership identification through "My Account -- Account Management" on the website.

You can also use your miles to redeem products in Phoenix Miles Mall. In this case, you will need to provide the recipient's full name, contact number, and mailing address. You may also voluntarily provide frequently used contact information and recipient information. We will send your recipient information to mall merchants and logistics service providers. If the recipient cannot be reached, we may provide your contact details to the merchant.

If you participate in membership products, activities, and use mileage payment functions, as well as mileage rewards or rights activities provided by our business partners, it will be deemed that you agree that we collect and use your name, ID type, ID number, contact number, email address, travel information, and member information for product activity statistics and membership services.

In addition, when you modify key personal information, redeem virtual goods, or click real-name authentication, you may be required to verify your identity using Alipay authentication, WeChat authentication, China UnionPay authentication, or mobile phone verification to confirm the operation is performed by you. If you refuse to provide the aforementioned information, you will only be unable to use the corresponding functions, but this will not affect your use of our other products and services.

(5) To provide you with identity authentication services

If you use the Student Identity Authentication Service, we may collect your name, ID number, mobile phone number, student ID picture, region, school name, and time of attendance at school, student ID number, and referrer (optional). If you use the teacher identity authentication service, we may collect your name, ID number, mobile phone number, and picture of your teacher qualification certificate, picture of your professional title appointment certificate, teaching institution, and region. If you use the International Student Identity Authentication Service, we may collect your name, ID type, ID number, expiration date, place of issuance, date of birth, gender, country/region, mobile phone number or email address, admission letter or student visa, or student ID picture, and frequent flyer program (optional). If you use the labor identity verification service, we may collect your name, certificate type, certificate number, expiration date, place of issuance, date of birth, gender, country/region, mobile phone number or email address, labor certification or labor visa picture, ID validity period, and frequent flyer program (optional). If you use the Seafarer Identification Service, we may collect your name, certificate type, certificate number, expiration date, place of issue, date of birth, gender, country/region, mobile phone number or email address, seafarer's certificate photo, and frequent flyer program (optional). If you use the enterprise identity authentication service, we may need to collect your email address. (Please note: Your identification document information is considered sensitive personal information in China.) If you refuse to provide the aforementioned information, you will only be unable to use the corresponding functions, but this will not affect your use of our other products and services.

(6) Other services provided to you

If you need to apply for special services for unaccompanied children, wheelchair passengers, blind passengers, and deaf-mute passengers, you need to fill in your name, contact information, ID number, contact information and address of the relevant accompanying person or pick-up person. We will verify your medical certificate (Please note: Medical health information is sensitive personal information) or collect relevant supporting documents in accordance with relevant national requirements. If you refuse to provide the aforementioned information, you will only be unable to use the corresponding functions, but this will not affect your use of our other products and services.

If you need to purchase our additional services, you will be required to provide your ticket number or ID number, name, flight number, and flight date.

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 contacting you, promptly assisting with problem resolution, or recording the handling and outcome of related issues, we may store your communications, call/communication records, and related content (including account information, order information, other information you provide to verify relevant facts, or contact details you provide). If you consult, complain, or offer suggestions regarding a specific order, we will use your account information and order information. When communicating with our customer service representatives, you may provide additional information beyond the aforementioned. For example, when you request us to update your delivery address, contact person, or phone number.

If there is a change to your flight or itinerary and you need to request a ticket refund or change, you will need to provide your ticket number or ID number, name, flight number, and flight date. If you apply for a free ticket refund due to illness and are unable to travel, we will require you to provide a medical certificate (Please note: Medical health information is sensitive personal information) for verification. If you refuse to provide the aforementioned information, this will only prevent you from using the above functions, but will not affect your use of our other products and services.

If you are an employee of one of our major clients (enterprises, government customers, etc.), we will retain your exclusive client agreement code in your booking record to ensure your ticket is purchased at the contractual exclusive price; your company's designated UATP (Universal Air Travel Plan) account information will also be kept with your booking; when you (or your company's contact person on your behalf) request major client exclusive services, we may require you (or your company's contact person) to provide your company name, job title, corporate email address, Phoenix Miles membership card number, contact details, ID type, ID number, date of birth, gender. If you have any questions, please first contact your company's designated contact person.

(7) Required to ensure transaction security

To enhance the security of our products and services when you use them, and to more accurately prevent phishing fraud and protect your account, we may identify account security or transaction risks by obtaining your browsing information and order information, as well as device information (such as IP address, device model, and device identifiers like IMEI, Android ID, OAID, GAID, UUID, IDFA, and IDFV), to help prevent fraud.

2. Information We Collect by Automated Means

When you access the Shenzhen Airlines App, Shenzhen Airlines WeChat Mini Program, Shenzhen Airlines Official Website, Shenzhen Airlines Mobile Official Website, Shenzhen Airlines Alipay Mini Program, Shenzhen Airlines Harmony Service Card, or Shenzhen Airlines WeChat Official Account, we may automatically collect specific information about you from your device for business, technical, or device-related reasons. The information we collect by automated means includes your:

(1) Device information: device model, operating system version, browser version, IMEI number, MAC address, IP address, port information, DNS, mobile carrier, data network standard, root status, network access method, login channel, app version, login time, hardware identifier, and other logs and technical parameters related to your network, system, and device; WiFi information (WiFi name), WiFi list, BSSID (WiFi MAC address), device sensor information (chromium) - linear acceleration sensor, light sensor, linear acceleration sensor, sensor list, process information (older versions), IMSI, list of installed apps, GAID, SIM card serial number (ICCID), SSID, precise location, device hardware serial number, screen height, screen width, unique app identifier, network type, country, and device manufacturer.

(2) Extensive geographic location information of the device (including location at the country or city level), as well as other technical information.

(3) We may also set up SDKs for the Website and our mobile applications to acquire your personal information and interaction information, including pages that you have visited and links you have clicked.

Please understand that this information is necessary for third-party services such as Aurora Push and Alipay to analyze device uniqueness and for security risk management purposes. We use this information for operational purposes, to help us better understand our visitors, and to improve our website's quality and relevance for visitors.

Some of this information is collected using cookies and similar tracking technologies, as described in "II. How Does Shenzhen Airlines Use Cookies and Similar Technologies."

3. When We Obtain Your Consent

(1) We will invite you to enable certain permissions on your mobile device. You can use related features based on the permissions you independently authorize in your device's operating system. If you do not enable the relevant permissions, you will only be unable to use the corresponding features or services, but your normal use of other features will not be affected. Please note. These permissions may vary depending on the operating system of your mobile device.

For details about the permissions we request and their intended use, see the Device Application Permission List.

(2) We will use the email address you provide to send you order and flight information, or to subscribe you to our promotional messages, including discounts for specific air routes, products, or services. By voluntarily submitting your information, you will be deemed to have agreed to receive these communications. We may also organize promotional events for which we need to collect your name and contact information for the purpose of completing these promotions.

(3) If you are an employee of one of our major clients (such as corporate or government customers), you may complete enterprise customer identity verification and select related services. You may voluntarily choose to agree to or cancel this verification.

(4) If you provide third-party information or sensitive information in the above functions, please make sure you have obtained full authorization from the third party that your actions do not infringe any legal rights of third parties, and that third parties can have their data processed in accordance with the Privacy Policy. If a third party requests the deletion or correction of relevant information, you must promptly delete or correct the information mentioned above. Otherwise, you may bear the legal consequences that arise as a result. If we need to change the purpose for which we use a third party's information due to business needs, we will promptly inform you. Please decide whether this information can continue to be processed according to the third party's authorization.

In addition, when you follow our official accounts on WeChat, Weibo, or other social media platforms, your active action of following will be regarded as your valid consent. We can identify the specific follower's information and the time of following, but we will only use it to interact with you on the platform. You may withdraw your consent at any time by unfollowing.

4. When Fulfilling Legal Obligations

To fulfill applicable laws and regulations, such as the requirements of relevant civil aviation laws and regulations, we will require you to provide your real name, ID type, and ID number information. To fulfill our network security obligations under China's Cybersecurity Law, we collect and store your log information.

Additionally, in the event of sudden public health incidents, we may collect and use your personal information according to law, in specific situations, to protect your life, health, and property rights.

(II) Information we collect from third parties

The information we collect from third parties covers that from professional travel agencies and others pertaining to ticket booking and travel arrangements. We use information from third parties to provide services for you and ensure that we have accurate records relevant to you. Additionally, in the event that you must go through identity authentication before requesting services, you have to verify your identity through biometric identification supported by our third-party partners. In this case, we do not collect or store your facial information and only request the authentication result from the third party. Please note that a third party may have its own privacy policy that explains how it collects and processes your personal information. Such a privacy policy does not constitute part of Shenzhen Airlines' Privacy Notice. Please read it carefully and make your own decision regarding consent.

II. How Does Shenzhen Airlines Use Cookies and Similar Technologies

We use Cookies and similar tracking technologies (collectively referred to as "Cookies") to collect and use your personal information. For more information on the types of Cookies we use, why we use Cookies, and how to control Cookies, please refer to our Cookie Statement for further details.

III. To Whom Does Shenzhen Airlines Share, Transfer, or Disclose Your Personal Information

(I) Share

We may share your information with partners and third parties to ensure smooth completion of the services provided to you. However, we will only share your personal information for lawful, proper, necessary, specific, honest, and clear purposes, and only share the personal information necessary to provide the services. We will assess the legality, propriety, and necessity of third parties collecting your personal information, and require third parties to process your personal information within the scope of your authorized consent and to take necessary information management measures and technical means to prevent your personal information from being leaked, damaged, lost, or altered. Third parties are not permitted to use the personal information you share for any other purpose. If they intend to change the purpose or method of processing your personal information, we will seek your renewed consent.

We may share your personal information with the following types of entities:

1. Group company and affiliated companies

To facilitate and manage your travel arrangements and to provide the products or services you request, we may share your personal information with our Group Company, subsidiaries, or affiliates for service and management purposes. For example, for Air China Limited ("Air China") to manage the Phoenix Miles Frequent Flyer Program and provide you with frequent flyer services (such as Phoenix Miles Mall services), we will share your frequent flyer information with Air China.

2. Our service providers and our affiliates

We may allow our third-party service providers (including agents, contractors, and affiliates) to use your personal information on our behalf, and they will process your data for the purposes described in this Privacy Policy and according to our instructions. Examples of such third parties include staff who assist you with check-in and boarding, and our system service providers. We may also disclose your personal information to third parties to make it easier for them to carry out any special arrangements you may request.

3. Star Alliance Services GmbH, other airlines, hotel partners, tour operators, travel agencies, insurance companies, banking and financial institutions, ground or maritime transport operators

To facilitate and manage your travel arrangements and provide you with the required products or services, we may share your personal information with third parties, such as other airlines (including Star Alliance partner airlines, other cooperating partners, and code-share airlines), hotel partners, ground or maritime transport operators, cooperating insurance companies or banking and financial institutions, and travel agencies or other persons interacting with us on your behalf. Your personal information will be used by these third parties in accordance with their privacy policies.

4. Phoenix miles membership program partners

We may share your information with airlines and partners participating in the Phoenix Miles membership program to facilitate your access to our Phoenix Miles member products and services, such as your mileage points accumulation and redemption, and lounge access.

5. Our major clients (enterprises, government customers, etc.)

If you are an employee of our major clients or go on a business trip or receive products and services by virtue of your status as an employee of our major clients, we will disclose your travel details and information about your use of our services to the said clients.

6. Regulatory bodies or entities as required by law

We may disclose your personal information to government and regulatory authorities, as well as organizations required by law, such as exit and entry authorities, customs and border protection agencies, the Civil Aviation Administration of China, airport management authorities, dispute resolution agencies, prosecutorial authorities, and law enforcement agencies. For example, laws in the United States and other countries/regions may require us to disclose your personal information related to your travel documents, booking details, and flight itinerary (Passenger Name Record (PNR) and/or Advance Passenger Information (API)) to these authorities as required by law. We will disclose your personal information to these authorities to enable us to provide products and services to you while complying with legal and administrative regulatory requirements.

7. Our SDK provider

To enable you to receive information notifications, use third-party payment services, use map services, achieve one-click mobile number login, and access other service functions, our app embeds software development kits (hereinafter referred to as "SDKs") or similar applications from authorized partners. We use these SDKs through interfaces provided by the operating system. The names of these third-party SDKs, their providers, the purposes and categories of personal information they collect can be accessed via the Third-party SDK Details Page.

8. Anyone who has obtained your consent. This includes situations where you authorize others to use your personal information to book or manage your itinerary on your behalf.

(II) Transfer

1. With your explicit prior consent;

2. As required by laws, regulations, or mandatory administrative or judicial requirements;

3. According to laws, regulations, and business practices, if your personal information needs to be transferred during mergers, acquisitions, asset transfers, or similar transactions, we will require the new company or organization that receives your personal information to continue to be bound by this Privacy Policy. Otherwise, we will request that the company or organization obtain your authorization and consent again.

(III) Public disclosure

1. We will not publicly disclose your personal information. If disclosure is necessary, we will obtain your consent and inform you of the purpose and type of personal information to be disclosed; if sensitive information is involved, we will also inform you of the content of the sensitive information and seek your explicit consent in advance.

2．Please understand that we may publicly disclose your personal information if required by laws, legal procedures, litigation, or mandatory requests from competent government authorities.

(IV) Exceptions to obtaining consent

According to Article 13 of the Personal Information Protection Law of the People's Republic of China, personal information may be processed without obtaining personal consent under the following circumstances:

1. Necessary for entering into or performing a contract in which you are a party, or for implementing human resources management according to legally established labor regulations and lawfully signed collective agreements;

2. Necessary for performing statutory duties or obligations;

3. Necessary to respond to sudden public health events, or in emergencies, to protect the life, health, and property of natural persons;

4. Necessary for conducting news reporting or public opinion supervision in the public interest, and for processing personal information within reasonable limits;

5. Processing personal information that individuals themselves disclose or that has otherwise been lawfully disclosed, within reasonable limits as stipulated by the Personal Information Protection Law of the People's Republic of China; and

6. Other circumstances specified by laws and administrative regulations.

IV. Rules for Shenzhen Airlines in Using Your Personal Information

We will use the personal information collected according to the Privacy Policy, and for enabling the functions of our products and/or services. Please note that all the personal information you provide for using our products and/or services, or sensitive information collected with your consent, will be continuously valid for us to use unless you delete or withdraw your consent, or refuse us to collect the said information through system settings. After you withdraw your consent or close your account, we will stop using your personal information and remove it.

We register the usage data on our products and/or services and may share such data with the public or third parties to demonstrate the overall use trend of our products and/or services. However, the statistical data does not contain any information that identifies you.

Your personal information will be displayed in a way that protects your information security after being masked by means of content replacement and anonymization.

To use your personal information for purposes other than those specified in the Notice or use your information for a purpose not clarified at the moment of collection, we will ask for your consent in advance and you will decide at your discretion.

V. Legal Basis for Shenzhen Airlines to Process Your Personal Information

We will not process your personal information without any legal basis. In general, the legal bases for our processing of your personal information are as follows:

Fulfill our contract with you, such as the General Terms of Carriage, the service agreements for specific products, and the Phoenix Miles Membership Manual;
Comply with and fulfill our statutory obligations, such as those required by civil aviation laws and regulations;
Obtain your consent, for example, when you allow us to send you promotional messages.
Respond to public health emergencies or protect your or other individuals' life, health, and property. For example, at the boarding gate, we may require you to undergo a temperature check, record passengers with abnormal temperature readings, and report them to the competent authorities for follow-up.
Within the European Union or European Economic Area, we process your personal information based on our legitimate interests, including managing your information in our information systems, improving our products and services, carrying out our Phoenix Miles Program member activities, participating in our social activities, implementing anti-fraud measures for transaction security, and ensuring network information security. On this basis, you have the right to object to or restrict our processing of your personal information.

VI. How Does Shenzhen Airlines Protect and Store Your Personal Information

(I) Technologies and measures we use to protect your personal information:

We attach great importance to the security of personal information and will take all reasonable and feasible security control measures to protect your personal information:

1. We have implemented industry-standard security measures to protect the personal information you provide and to prevent unauthorized access, disclosure, use, modification, damage, or loss of your data. We use Transport Layer Security (TLS) encryption and strong password algorithms to ensure the security of data during transmission; we use industry-standard strong encryption technologies to encrypt stored personal information; and we use detachment technology to detach and protect your information. All access to stored data is recorded and saved in relevant logs. Through centralized log collection and integrity monitoring, we ensure that log files cannot be tampered with. Additionally, we routinely conduct internal and external security scans and penetration tests to ensure the security of our production systems.

2. We have obtained the following certifications: our e-commerce system has passed the Level 3 Protection Certification for Information Systems of the People's Republic of China, and we have also obtained ISO27001 and PCI DSS certifications.

3. We have designated a Personal Information Protection Officer who fully supervises our personal information compliance work. We have also appointed a Data Security Officer and set up a working group to advance and safeguard data security. We regulate the collection, transmission, use, and storage of personal information through our established information security management system. We sign confidentiality agreements with our employees, requiring personnel who may have access to personal information to fulfill their confidentiality obligation. We regularly carry out training on information security and personal information protection to enhance employees' awareness of the importance of protecting personal information.

4. The Internet is not an absolutely secure environment, and we strongly recommend that you do not send personal information over the Internet. Please use a complex password to help us protect the security of your account.

5. To address possible risks such as personal information leakage, damage, and loss ("personal information security incidents"), we have formulated emergency response measures for personal information leakage, established an emergency plan for personal information security incidents, and set up a dedicated emergency response team. We will notify regulatory authorities and/or affected passengers of any personal information leakage incidents in accordance with applicable laws and regulations.

(II) The retention period of your personal information

We will store your personal information for the shortest period necessary to achieve the purposes described in this policy, unless otherwise required by applicable laws and regulations. After you close your account, we will also delete or anonymize your personal information. When your personal information exceeds the minimum retention period necessary for the purposes described above, we will delete or anonymize your personal information.

VII. Protecting the Personal Information of Minors

1. Laws in different jurisdictions set different age requirements for minors ("children") to be able to give consent. If you are under 14 years old in China, or considered a child in other jurisdictions (for example, under 16 in the European Union, or under 13 in the United Kingdom), you must obtain written consent from your parent or legal guardian before using our products or services. Shenzhen Airlines protects minors' personal information in accordance with relevant laws and regulations.

2. Additionally, we will only process the minimum information required for the products and services purchased by children and ensure that appropriate security measures are taken. We promise not to make portraits of children, send promotional information to them, or exploit their personal information to induce them to conduct activities that do not fit their ages and responsibilities.

3. For personal information of children collected with the consent of their parents or legal guardians, we will only use or disclose this information if it is permitted by laws, expressly agreed by their parents or legal guardians, or required for protecting children.

4. If children provide us with their personal information without the consent of their parents or legal guardians, their parents or legal guardians may send an email to dpo@shenzhenair.com to remove such information or cancel any reserved promotional activity contact opportunities.

For more details regarding the protection of children's personal information, please refer to the Children's Personal Information Protection Rules of Shenzhen Airlines.

VIII. How Is Your Personal Information Transmitted Globally

The personal information we collect and generate within the People's Republic of China will be stored within the country.

For the purposes described in this Privacy Policy, your personal information may be transferred and processed in countries or regions outside your habitual place of residence. In such cases, we will protect your personal information according to applicable legal provisions and when transferring your personal information globally, including but not limited to the following measures:

1. If your personal information is transferred outside of the People's Republic of China, we will comply with legal and regulatory requirements and perform the necessary statutory procedures to ensure your personal information is transferred lawfully and compliantly. You can click here to obtain detailed information regarding the outbound transfer of data.

2. If your personal information is transferred by Shenzhen Airlines from the European Union to a country or region where the European Commission has not made an adequacy decision, we will sign European Commission-approved standard contractual clauses with the recipient and take security measures to safeguard your personal information.

IX. Your Rights to Personal Information Protection

You have the following rights:

1. Query your personal information

You have the right to query your personal information. Specifically, you can access it by:

(1) Your account information:

Log in to the Shenzhen Airlines app and tap Me - Name to view Basic Information and Contact Information. You can also view more personal information on the Me page.

Log in to the Shenzhen Airlines website, and click your personal account in the upper-right corner to query your personal information.

Log in to the WeChat Mini Program of Shenzhen Airlines, and tap Me in the lower-right corner to query your personal information.

Log in to the Shenzhen Airlines mobile website and click "My Shenzhen Airlines" in the lower right corner to query your personal information on the interface.

(2) Your membership information:

Log in to the official Shenzhen Airlines website and go to "Member Services - Account Management" to query your membership and mileage information.

Log in to the Shenzhen Airlines WeChat Mini Program and check your membership and mileage information via "Phoenix Miles".

Log in to the Shenzhen Airlines mobile website, then click "My Shenzhen Airlines - Phoenix Miles Service" in the bottom right corner to check your membership and mileage information.

(3) Your order information:

Log in to the Shenzhen Airlines official website and check your order information via "Flight Booking - Order Management".

(4) If you need to inquire about other personal information generated while using our products and/or services, you can contact us by calling 95361/0086-755-88814023, or emailing dpo@shenzhenair.com. We will typically reply within 15 business days.

2. Obtain a copy of your personal information and transfer your personal information

You have the right to request a copy of your personal information processed by us, and, subject to legal or regulatory requirements, you also have the right to request us to transfer your personal information to another processor designated by you. However, please note that under the GDPR (General Data Protection Regulation of the European Union), if you request to exercise your right to data portability, we will make every effort to provide you with a copy of your data as requested. However, it can be technically difficult to transfer structured, commonly used, and machine-readable formatted data to another controller. You can contact us by calling 95361/0086-755-88814023, or emailing dpo@shenzhenair.com. We will typically reply within 15 business days.

3. Restrict automated decision-making by information systems

While providing you with personalized services, we may in certain scenarios use automated decision-making mechanisms (that is, decisions made solely through information systems, algorithms, or other non-human means that automatically analyze and evaluate your personal information to make decisions). The scenarios include:

Automatically issue exclusive coupons to you during your birthday month based on your birthday information;

Provide you with exclusive prices based on your age information;

Provide you with exclusive prices or services based on your membership status and identity verification information;

Assess whether you are eligible to participate in specific activities (such as the "Flying Master Badge Challenge," "Family Travel Plan," "Shenzhen Airlines Co-branded Card Activities," and "Reward Ticket Challenge Activities") and determining the results of those activities.

We are committed to ensuring that the implementation of the above automated decisions follows the principles of fairness, impartiality, and transparency, and that you will not be subjected to unreasonable differential treatment regarding transaction prices or other transaction terms.

Under relevant laws and regulations, you have the right to request explanations of the results of automated decision-making, and the right to refuse decisions that are made solely through automated decision-making and have a significant impact on your personal rights and interests. If you object to the results of automated decision-making or wish to refuse such decisions, you can contact us by calling 95361/0086-755-88814023, or emailing dpo@shenzhenair.com. We will typically reply within 15 business days.

4. Correct or supplement your personal information

If you find that the personal information we process about you is inaccurate and affects your rights, you have the right to request us to correct or supplement it at any time. You can apply for corrections on the personal information inquiry page or through the relevant channels. If you still have questions or are unable to make corrections, you can contact us by calling 95361/0086-755-88814023, or emailing dpo@shenzhenair.com. We will typically reply within 15 business days.

5. Delete your personal information

In the following situations, you may request the deletion of your personal information by calling 95361 / 0086-755-88814023 or emailing dpo@shenzhenair.com. We will typically reply within 15 business days:

(1) If our processing of personal information violates any law or regulation;

(2) If we collect and use your personal information without your consent;

(3) If our processing of your personal information breaches the agreement with you;

(4) If our purpose has been fulfilled, cannot be fulfilled, or it is no longer necessary to fulfill the purpose;

(5) If we stop providing products or services, or if the data retention period has expired;

(6) If you no longer use our products or services, or have closed your account;

(7) If you withdraw your consent;

(8) Other circumstances specified by laws and administrative regulations.

If the retention period specified by laws and administrative regulations is not expired, or it is difficult to technically delete the personal information, we will stop performing operations other than those for retention and necessary security protection.

6. You have the right to close your account.

You have the right to close your account registered with Shenzhen Airlines. Once you choose to close your account, we will securely delete or anonymize your personal information (except for any personal information we are required by law to retain for a minimum period).

If you choose to close your Shenzhen Airlines account, you can do so by "Shenzhen Airlines App -- Me -- Settings -- Account Security -- Permanently Close Shenzhen Airlines Account" or "Shenzhen Airlines WeChat Mini Program -- Me -- Close Account". After you close your Shenzhen Airlines account, we will stop providing the relevant products and/or services. Unless otherwise provided by laws and regulations, all information, rights, wallet accounts, and family accounts associated with your Shenzhen Airlines account will be deleted and cannot be recovered. After you submit a request to close your Shenzhen Airlines account using the Shenzhen Airlines App or Shenzhen Airlines WeChat Mini Program, Shenzhen Airlines will complete the account closure within 7 business days. During this period, you will not be able to register, log in, or use this account.

If you choose to close your Phoenix Miles membership account, you can apply for account closure through "Shenzhen Airlines App - Phoenix Miles - Account Management - Close Phoenix Miles Account", or "Shenzhen Airlines WeChat Mini Program - Phoenix Miles - Account Management - Close Phoenix Miles Account", or "Shenzhen Airlines official website - Member Services - Account Management - Phoenix Miles Service - Permanently Close Account". After you close your Phoenix Miles membership account, we will stop providing the corresponding products and/or services to you, and according to your request, unless otherwise stipulated by laws and regulations, we will delete your personal information in the membership account, and your mileage will also be cleared. After you submit a request to close your Phoenix Miles membership account via the Shenzhen Airlines App or Shenzhen Airlines WeChat Mini Program, Shenzhen Airlines will immediately close your Phoenix Miles account.

7. Agree or refuse our sending of promotional information.

You have the right at any time to agree or refuse our sending of promotional information. On the Shenzhen Airlines App, you can select whether to agree or refuse the promotional information we send to you by clicking "Me - Messages - Settings - Message Settings".

You can at any time cancel your following or unsubscribe from our official WeChat public account, Weibo, and other official social media accounts.

8. Restrict or refuse the processing of your personal information

You have the right to refuse our processing of your personal information, the right to require us to limit the processing of your personal information, request portability of your personal information, or request an explanation of the personal information processing rules. You can contact us to exercise these rights by calling 95361/0086-755-88814023 or emailing dpo@shenzhenair.com. We will typically reply within 15 business days.

If we have collected and processed your personal information with your consent, you have the right to withdraw your consent at any time. You may withdraw your consent by contacting us via 95361/0086-755-88814023 or by emailing dpo@shenzhenair.com. We will typically reply within 15 business days. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect our processing of your personal information conducted based on lawful grounds other than your consent.

9. Exercise of rights

To ensure your information security, we may require you to provide a written request or verify your identity. We will respond to your rights request within a reasonable period permitted by law. In addition, according to the Personal Information Protection Law of the People's Republic of China, if you exercise rights on behalf of others, or if you are a close relative of a deceased individual and request to inquire about, copy, correct, or delete information related to the deceased, please provide proof of identity for both yourself and the other party, as well as proof of your relationship, such as a special power of attorney or a death (presumptive death) certificate of the deceased.

We respond to all requests we receive from individuals wishing to exercise their personal information protection rights in accordance with applicable laws. In general, for requests made through our China App or Mini Program, we will respond to and process your access, correction, deletion, or closure requests within fifteen business days. We will ask for your information to verify your identity in order to ensure the personal information security of our passengers. In the European Union or the United Kingdom, we will respond to your request regarding your personal data rights within one month. If your request is especially complex and an extension of the response time is required by law, we will promptly notify you in accordance with applicable law.

You have the right to file a complaint or take legal action with the supervisory authority or court in your usual place of residence or the place where the relevant conduct occurred, regarding the exercise of the above rights or our response.

X. Updates to the Privacy Notice

Please understand that we may revise this Privacy Policy from time to time. We will indicate the date of the latest update, and the revised policy will take effect upon publication. Without your explicit consent, we will not reduce the rights you are entitled to under this Policy. For significant changes, we will also provide more prominent notice (such as clearly informing you of Privacy Policy updates via pop-up notifications in our App and Mini Program). Please visit this Policy regularly to read the latest version.

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

1. Where our service model undergoes significant changes, for example, changes to the purpose for processing personal information, the types of personal information processed, or how personal information is used;

2. Where there are major changes in our ownership structure or organizational structure, for example, changes in ownership caused by business adjustments, bankruptcy, mergers, or acquisitions;

3. Where there are changes to the main parties with whom personal information is shared, transferred, or publicly disclosed;

4. Where there are major changes to your rights regarding personal information and the ways you can exercise those rights;

5. Where there are changes to the department responsible for personal information security, contact details, or complaint channels; or

6. Where a personal information security impact assessment report indicates a high risk.

To fully ensure your right to information, we also provide historical versions of this policy. You can click here to access them.

XI. How to Contact Us

1. If you have any questions or concerns about our use of your personal information or wish to exercise your right to personal information protection, please contact us at:

Personal Information Protection Officer's email address: dpo@shenzhenair.com

Contact number: 95361 (Chinese mainland); 0086-755-88814023 (Hong Kong (China), Macao (China), and Taiwan (China) regions, and overseas)

Contact address: Shenzhen Airlines Base, No. 2033, Hangzhan 4th Road, Bao'an District, Shenzhen

You can also contact us at any time through the "Online Customer Service" feature on the Shenzhen Airlines official website, Shenzhen Airlines App, Shenzhen Airlines WeChat Mini Program, Shenzhen Airlines Mobile Website, or Shenzhen Airlines Alipay Mini Program.

2. Under normal circumstances, we will respond within 15 business days. If you are dissatisfied with our response, especially if our personal information handling has harmed your legitimate rights and interests, you may also lodge a complaint with the Cyberspace Administration of China, Consumer Protection Association, or other regulatory authorities. The complaint channels are as follows:

(1) Cyberspace Administration of China Whistleblowing Report Center: www.12377.cn

(2) Consumer complaint and whistleblowing report hotline: 12315