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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

Latest Update: 19 May, 2025

Shenzhen Airlines Co., Ltd. (hereinafter referred to as "we" or "Shenzhen Airlines") understands the importance of protecting passenger personal information, and we will take appropriate security measures in accordance with legal requirements. Through this privacy policy, we aim 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 cookie and similar technologies

3. With whom does Shenzhen Airlines share, transfer, and disclose your personal information

4. Rules for the use of your personal information by Shenzhen Airlines

5. Legal basis for the processing of your personal information by Shenzhen Airlines

6. How does Shenzhen Airlines protect and store your personal information

7. Protection of personal information of minors

8. How is your personal information transferred globally

9. Your rights in the protection of your personal information

10. Updates to this privacy policy

11. How to contact us

Before using our products or services, please read and understand this privacy policy carefully, and use the relevant products or services only after fully understanding. If minors are using our services, please read and understand this privacy policy with the accompaniment and assistance of their parents or guardians.

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

(Ⅰ)We will request your voluntary provision of personal information for the following purposes

1.To fulfill the airline transportation contract between you and us:

(1)Seat reservation and ticketing services

In order to complete your seat reservation and ticket purchase, we need you to provide the following information: passenger name, gender, valid identification information (notice: in China, identification information is considered sensitive personal information), date of birth, contact phone number, email address (required for overseas ticket purchase), contact person's name, and contact phone number. If you book a flight that goes through or from/to the territories of the United States, you will also need to provide residential address information at the point of origin and destination, as required by local regulations.

To complete the payment, we require the following payment information (notice: in China, financial account information is considered sensitive personal information): bank card number, expiration date, CVV, billing address, cardholder's name, bank reserved mobile number, valid identification information, mileage payment password, Shenzhen Air Pay account information, personal account information provided by online payment platforms (such as Alipay, WeChat Pay), payment results, transaction records, device information, IP, and network information. You understand that we need to share your order, transaction amount, and transaction information required by your chosen payment institution with them.

After purchasing the ticket, we will generate your order information, and the ticket order information will include your seat reservation records, ticket number, flight number, origin, destination, boarding time, cabin class, etc.

If you need to receive an itinerary by mail, you need to provide the recipient's name, contact phone number, and mailing address. If you request an electronic invoice, you 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 also need to provide company name and taxpayer identification number information.

(2)Registration and Usage of the Shenzhen Airlines Shenfen (loyal customers) services

When you use our Shenfen services, you need to provide information such as your name, ID number, gender, date of birth, mobile phone number, email address, Shenfen password, etc. for registering and logging into the Shenfen account.

(3)Registration and Usage of the PhoenixMiles services

If you choose to register as a PhoenixMiles member, you need to provide your name, contact phone number, valid identification information, country/region, date of birth, and password. We will provide you with a "PhoenixMiles" membership card number and your membership level. When you use the PhoenixMiles, your mileage accumulation and redemption information will be generated, including your knowledge mall order records. Your membership level may change according to the rules of the membership level.

If you are a minor under the age of 14, you need to provide the associated guardiancard number. In addition, you can voluntarily provide other information, such as an email address (for sending service or marketing emails), choosing whether to receive promotional information, interests, and preferences (seating and meals).

To avoid the trouble of entering information, we will directly extract some information from the application form or during the processing flow. This includes your registration date, registration channel, preferred communication language, and member brand. You can use your mileage to redeem reward tickets for yourself and your transferees, which requires you to provide the information required for seat reservation and ticketing services. As a supplementary way to accumulate mileage, we have initially enabled the automatic identification service for member card numbers for all members. That is, when members use the China Aviation Information Group's system to purchase Shenzhen Airlines-operated flight tickets, if the passenger's name and valid identification number match the information registered in the member account, the member card number will be automatically identified, and the flight taken may be automatically accumulated. If you do not want the automatic identification service, members can log in to the PhoenixMiles website's member account and close the automatic identification of member status through "My Account - Account Management".

You can also use your mileage to redeem goods in the Knowledge Mall, which requires you to provide the recipient's name, contact phone number, and mailing address. You can also voluntarily provide commonly used contact information and recipient information. We will send your recipient information to merchants in the mall and logistics service providers. If we cannot contact the recipient, we may provide your contact information to the merchant.

If you participate in member products, activities, use mileage payment functions, and mileage rewards or benefits provided by our business partners, it will be considered that you agree to our collection and use of your name, identification information, contact phone number, email address, itinerary information, and member information for product activity statistics and member services.

In addition to the above, when you modify key personal information, redeem virtual goods, or click on real-name authentication, you may need to confirm whether the operation is performed by you through Alipay authentication, WeChat authentication, UnionPay authentication, mobile phone verification, etc.

(4)Identity verification services

If you use our identity verification services, we may collect your name, gender, ID number, phone number, identity certificate image, bank card information, student ID, teacher ID, and other personal information to complete identity verification. (Please note that in China, your relevant identification document information is considered sensitive personal information).

(5)Other services

If you need to apply for special services such as stretchers, wheelchairs, unaccompanied minors, or transportation of donated organs, you need to provide your name, contact information, valid identification information, contact information and address of relevant accompanying persons or pick-up/drop-off persons. We will verify your medical certificate(Please note that medical health information is sensitive personal information.) or collect relevant supporting documents according to national requirements.

If you need to purchase our prepaid baggage and paid seat selection services, you need to provide the ticket number or valid identification information, 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 security, our call center and online customer service will use your account information to verify your identity. When you need us to provide customer service and after-sales service related to your order information, we will retrieve your order information. In order to contact you, help you solve problems as soon as possible, or record the handling plan and results of related issues, we may save your communication, communication/call records, and related content (including account information, order information, other information you provide to prove relevant facts, or contact information you leave). If you consult, complain, or provide suggestions regarding specific orders, we will use your account information and order information. You may provide other information to our customer service staff during communication, such as when you request a change of delivery address, contact person, or contact phone number.

If you apply for a full ticket refund without charge due to illness preventing you from traveling, we will need you to provide a medical certificate for verification.

If you are an employee of our major clients (enterprises, government clients, etc.), to ensure that the tickets you purchase are exclusive to the agreed-upon price under the agreement, we will retain exclusive major client agreement code information in your reservation record; information about the enterprise UATP (Universal Air Travel Plan) account designated by your organization will be retained in the reservation information; when you (or the contact person of your organization) apply for the use of major client exclusive services, we may need you (or the contact person of your organization) to provide personal information such as the name of your organization, position, corporate email address, PhoenixMiles card number, contact information, valid identification information, date of birth, etc. If you have any questions about this, please first contact your organization's contact person to express your demands.

(6)Necessary for transaction security

To improve the security of our systems when you use our products and/or services, and to more accurately prevent phishing website fraud and protect account security, we may use your browsing information, order information, device information (IP address, device model, device identification number), etc. to assess the security of your account/transaction security risks and prevent fraud.

2.Information Automatically Collected

When you access the Shenzhen Airlines app, Shenzhen Airlines WeChat Mini Program, Shenzhen Airlines official website, Shenzhen Airlines mobile website, Shenzhen Airlines Alipay Mini Program, Shenzhen Airlines HarmonyOS Service Card, Shenzhen Airlines WeChat Official Account, we may automatically collect specific information related to you from your device for business, technical, and device-related reasons. The information automatically collected may include:

(1)Device information: device model, operating system version, browser version, IMEI number, MAC address, IP address, port information, DNS, mobile network operator, data network standard, root identification, network access method, login channel, app version number, login time, hardware number, and other log information, technical parameter information related to user networks, systems, and devices.

(2)General geographic location of the device (including country or city-level location) and other technical information.

(3)We may also use SDKs on websites and mobile applications to collect your personal information and information about website interactions, including the webpages you have visited and the links you have clicked on.

Please understand that this information is necessary for device uniqueness and security risk control in services like JPush and Alipay and other third-party analysis. We use this information for operational purposes to better understand our visitor demographics and enhance the relevance of our website to visitors.

Some of this information may be collected using cookies and similar tracking technologies, as described in the section "Ⅱ. How Does Shenzhen Airlines use cookie and similar technologies" below.

3.Obtaining Your Consent

To enhance your service experience and improve our products and services, we may ask for your voluntary consent to collect and use your information.

(1)Our app may request specific permissions on your mobile device to provide better service experience or improve our products or services. We will seek your consent before obtaining the corresponding permissions. You can disable the permissions through the settings of your device's operating system. The device permissions we may obtain and their purposes include:

Notification permission is used for enabling system notifications and receiving message notifications, such as flight information and promotional activities after placing an order;

Location permission is used for current city positioning, to facilitate services such as flight booking and airport transfers;

Contacts permission is used for convenient access to your contact information during ticket purchase, eliminating the need for manual input (name and phone number) of contact information from your address book and notifying you of ticketing information;

Camera/Album permission is used for functions like taking photos in flight updates, scanning and recognizing QR codes for coupon discounts, and document identification;

Call permission is used for making customer service calls from your device;

Storage permission is used for functions like image storage and upload, reading/writing personal settings information, creating system and log files, caching itineraries/screenshot sharing/saving images to the album, etc;

SMS sending permission is used for personal identity verification, to facilitate services related to account benefits.

If you refuse to grant the corresponding permissions, it will only result in your inability to use the corresponding functional services, but it will not affect your normal use of other functions. If you need to turn permission granting on or off, please follow the steps below: Open the phone settings - find “ShenZhen Airlines” in the application list and click to enter, then view or modify the permission setting.

(2)We may ask for your email address to send order and flight information or subscribe to our promotional information, including discounts on specific routes, products, or services. You can freely choose to provide the information or not .We may also organize promotional activities that require collecting your name and contact information to complete these activities.

(3)If you are an employee of our major clients (enterprises, government clients, etc.), you can choose to authenticate as a corporate client and select services. You can voluntarily choose to agree to or cancel the authentication.

(4)Please ensure that when providing third-party information and sensitive information in the above functions, you have obtained sufficient authorization from the third party, ensuring that your actions do not infringe upon the legal rights of any third party. At the same time, you should ensure that the third party can handle its data in accordance with the privacy policy. If the third party requests the deletion or correction of relevant information, you need to promptly delete and correct the above information, otherwise, you may bear legal consequences arising from this. If we need to change the purpose of using the third-party information due to business needs, we will inform you in a timely manner, and you can decide whether the above information can continue to be processed based on the authorization from the third party.

Additionally, when you actively follow our WeChat Official Account, official Weibo, and other social media platforms, your act of active following will be considered as valid consent. We may identify specific followers and their following time, but we will only use this information for interaction on the platforms. You can withdraw your consent at any time by unfollowing.

4.Compliance with Legal Obligations

To comply with applicable laws and regulations, such as requirements under civil aviation laws and regulations, we may require your real name and valid identification information. To fulfill our obligations related to network security levels under the Cybersecurity Law of the People's Republic of China, we may collect and store your log information, etc.

(Ⅱ)Information Obtained from Third Parties

We collect information from third parties, including professional travel agencies and other entities involved in ticket booking and travel arrangements. We use the information collected from third parties to provide services to you and ensure the accuracy of the relevant records we hold about you. Additionally, in some scenarios where verification is required to process relevant business, we may need you to verify your identity through third parties we cooperate with using personal biometric information. We do not collect or store your facial information ourselves, but only obtain identity verification results returned by third parties. Please note that third parties may have their own specific privacy policies explaining how they collect and process your personal information. These privacy policies are not part of Shenzhen Airlines' privacy policy, so please read them carefully and make your own decision on whether to agree.

In general, we will only use the personal information collected from you for the purposes described in this privacy policy or for the purposes explained to you when collecting your personal information. However, if permitted by applicable data protection laws, we may also use your personal information for purposes other than those informed to you (e.g., for archival purposes of public interest, scientific or historical research purposes, or statistical purposes).

Ⅱ. How Does Shenzhen Airlines Use Cookie 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 about the types of Cookies we use, why we use Cookies, and how to control Cookies, please refer to our "Cookies Statement" for more information.

Ⅲ. With Whom Does Shenzhen Airlines Share, Transfer, and Disclose Your Personal Information

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

1.Group and affiliated companies

To facilitate and manage your travel arrangements and provide the necessary products or services, we may share your personal information with our group and subsidiary companies for service and management purposes. For example, to manage the PhoenixMiles frequent flyer program and provide the services you need (such as PhoenixMiles E-Shop services), we may share your frequent flyer information with Air China.

2.Our third-party service providers

We will allow our third-party service providers (including ticket agents and third-party service providers who provide ground baggage, security, system services, payment, etc.) to use your personal information on our behalf for data processing purposes as described in this privacy policy and in accordance with our requirements. Examples of such third parties include staff assisting with check-in and boarding, and our system service providers. We may also disclose your personal information to third parties to facilitate any special arrangements you may request, such as airport transfer services.

3.Star Alliance, other airlines, hotel partners, tour operators, travel agencies, insurance companies, banking and financial institutions, and other third parties

To facilitate and manage your travel arrangements and provide the necessary products or services, we may share your personal information with third parties.

(1)This includes Star Alliance and other airlines (Star Alliance member airlines, joint ventures, and code-sharing partners) that provide services such as frequent flyer point sharing and airport lounge access, assist in transportation or rebooking in case of disruptions to your journey. We only share information with other airlines within the scope necessary to fulfill the contract between you and us.

(2)Hotel partners, ground or maritime transport operators, cooperating insurance companies or banking and financial institutions, and travel agencies or personnel representing you in interactions with us. These entities provide accommodation, travel, insurance, and other services.

(3)Cooperating social media tools (such as "WeCom") that provide you with ticket booking, order inquiry, travel services, and other related services.

Your personal information will be used by these third parties in accordance with their own privacy policies. We only share such information with these third parties to the extent necessary for providing the relevant services to you.

4.PhoenixMiles loyalty program partners

We may share your information with airlines and partners that jointly participate in the PhoenixMiles loyalty program to facilitate your enjoyment of our PhoenixMiles membership products and services, such as mileage accumulation and redemption, lounge access, etc.

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

For employees of our major clients or individuals who travel or obtain products and services through our major clients' payment, we will disclose your travel details and information related to your use of our services to our major clients.

6.Regulatory authorities or units required by law

We may disclose your personal information to government and regulatory authorities, as well as units required by law, such as immigration authorities, customs and border inspection authorities, civil aviation administrations and airport authorities, dispute resolution organizations, procuratorial organs, and law enforcement agencies. For example, U.S. and other countries/regions may require us to disclose your personal information (passenger name record (PNR) and/or advanced passenger information (API)) related to travel documents, booking details, and flight itineraries in accordance with legal requirements. We will disclose your personal information to these authorities and units to provide products and services to you in compliance with legal and administrative supervision purposes.

We may transfer your personal information to actual or potential acquirers of our business or any part thereof: If we engage in communications with actual or potential acquirers (and their agents and advisors) regarding any actual or proposed merger or acquisition of any part of our business, we will notify the buyer that your personal information should only be used for the purposes stated in this privacy policy.

Other individuals with your consent. This includes authorizing others to use your personal information on your behalf, such as making reservations and managing your itinerary.

Our SDK providers. We may share your personal information with the following SDK providers, but we will seek your consent before doing so. The specific information is as follows:

SDK Name Purpose of processing personal information Scope of collecting personal information Processing Method

CND

(Wangsu Science&Technology)

It is used for accelerating the access to static pages in the Shenzhen Airlines app, enhancing the loading speed of customer pages, ensuring the continuous and stable service of the Shenzhen Airlines app, and improving user browsing experience.

Usage analysis-related data, popular click ranking data, visitor analysis-related data, and status analysis-related data. Privacy Policy Link: https://www.wangsu.com/document/172/scesdkyszc

Information is collected through the SDK, and the SDK provider, provider is responsible for processing the information for the intended purpose ofto providinge corresponding functionality.

URORA

(Shenzhen Hexun Huagu Information Technology Co., Ltd.)

Push messages to devices for users, including service notifications, flight information, promotional information, customer service information, and member service information.

Types of collected personal information: Device parameters and system information (device type, device model, system version, and related hardware information):  used to identify the user's device type, device model, system version, etc., to ensure accurate message delivery;

Device identifiers (IMEI, IDFA, Android ID, GAID, MAC, OAID, VAID, AAID, IMSI, MEID, UAID, hardware serial number information, ICCID, SIM information): These are used to identify unique users, ensuring precise delivery of push notifications and accurate statistics of push information.

Network information (IP address, WiFi information, base station information, DNS address, DHCP address, SSID, BSSID) and location information (latitude and longitude): used to optimize the network connection requests between SDK and Jiguang servers, ensuring the stability and continuity of the service, while realizing regional push function.

Link to JIGUANG’s privacy policy

https://docs.jiguang.cn/jpush/client/Android/android_jghgzy

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose toof providinge corresponding functionality.

GeTui

(Merit Interactive Co., Ltd.)

Business purpose: to implement the one-click login function and verify the consistency between the user's login phone number and the membership login phone number. At the same time,  various cheating behaviors and risky devices can be effectively identified by analyzing the risk level of the current device, which can be used to evaluate channel quality, and identify some false behaviors to boost data and malicious programs, etc.

Types of collected personal information: device information, application list information, network information, and location-related information. Specific types of device information: device SSID, BSSID information, and device identification code will be used to generate a unique client ID, known as GYUID. Device platform, device manufacturer, device brand, device model, and other device-related information help us better identify the current device, enhancing our anti-fraud capabilities. Specific types of application list information, network information, and location-related information.

Link to Personalized User’s privacy policy:

http://docs.getui.com/privacy/

Information is collected through the SDK, and the SDK provider, is responsible for processing the information for the intended purpose to provide corresponding functionality.

WeChat

(Tencent)

Used to support WeChat payment and unified login; used to support sharing links and images to WeChat Moments.

Types of collected personal information: device identifiers (IDFA, OAID), login IP address, device model.

Link to WeChat’s privacy policy:

https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8

Information is collected through the SDK, and the SDK provider, is responsible for processing the information for the intended purpose to provide corresponding functionality.

Weibo

(Sina)

It is used for Weibo sharing and Weibo unified login.

Types of collected personal information: Device permissions called by the SDK: device identification information (IMEI, IMSI), network information (MAC address). Weibo SSO authorizes SDK to collect Android ID information.

Link to Sina Weibo’s privacy policy:

https://weibo.com/signup/v5/privacy

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

One-Click Login SDK

(China Mobile)

It is used for implementing one-click login.

Collection of personal information: network identity identifier, user service usage data. China Mobile Authentication Service Agreement. Specific types of network identity identifier, including registered mobile phone number, registered email, security email, local phone number; specific types of user service usage data, including mobile device identification code, International Mobile Equipment Identity, International Mobile Subscriber Identity, media access control address (MAC), device model, device manufacturer, network type and strength, application data, mobile operating system, screen size, screen resolution, IP address.

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

One-Click Login SDK

(China Telecom)

It is used for implementing one-click login..

Collection of personal information: client information, network IP address, network type. China Telecom Tianyi Privacy Policy. Specific types of client information, network IP address, and network type are used to complete the China Telecom Tianyi Account login authentication. When using the China Telecom Tianyi Account, we (China Telecom) collect your network IP address, network type through your cellular data network traffic capabilities. With the user's consent to change the network connection status permission in the program, the China Telecom Tianyi Account plug-in has the right to allow the program to change the network connection status and to access cellular data network and Wi-Fi network.

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

One-Click Login SDK

(China Unicom)

It is used for implementing one-click login.

Collection of personal information: network type, screen size, IP address, phone number. China Unicom Unified Authentication Service Terms and Conditions. Specific types of network type, screen size, IP address, phone number: In this agreement, "user information" refers to information that complies with laws, regulations, and relevant regulations and falls within the following scope (information obtained by China Unicom when the user uses this service, including network type, screen size, IP address, phone number). China Unicom does not store the above information, only uses it during user login.

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Page Monitor

(Sensors)

It is used for analyzing page and functional interaction design issues. To promptly discover design issues with page and functional interaction flows and provide users with a better interactive experience.

Collect advertising identifiers, IP addresses, operating systems, device information (including IMEI, Android ID, IDFA, IDFV, OAID, UUID, Mac address, IMSI information), page browsing and page interaction error information.

Privacy policy link:

https://manual.sensorsdata.cn/sa/latest/zh_cn/sdk-22255999.html

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Performance Monitor

(Tingyun)

This SDK serves as an application performance monitoring system, mainly used for monitoring various performance indicators of the Shenzhen Airlines app to promptly identify and locate issues that may arise during user interactions with the Shenzhen Airlines app.

Collect device information: device model, operating system version, device settings, Android ID, unique device identifier. Device location-related information: IP address, GPS location, Wi-Fi access point, Bluetooth, base station, and sensor information. Log information: search query content, IP address, browser type, telecommunications operator, language used, access date and time, and webpage access records.

Link to detailed privacy policy:

https://www.tingyun.com/ppa.pdf

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

UnionPay

It is used to provide UnionPay Cloud QuickPass, Apple Pay, and Android Pay functions for payment.

SDK device permission calls: Android: Information (device model, language, resolution, version, operating system name, system version number), merchant app package name, time zone, network connection method, baseband version, latitude and longitude, IMEI (International Mobile Equipment Identity), IMSI (International Mobile Subscriber Identity), MAC address, device communication number. iOS: Information name, device information (terminal language, resolution, version, operating system name, system version number), time zone, network connection method, ROOT used for checking business environment and risk control.

Link to China UnionPay’s Detailed Privacy Policy:

https://wallet.95516.com/s/wl/WebAPP/helpAgree/page/agreement/regPrivacy.html?cntryCode=86

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

QPOS

(YeePay)

It is used to support Shenzhen Airlines wallet balance, debit card, and credit card payments.

It may collect order-related information; may collect mobile phone number, name, identification number, etc., for registration and card binding verification.

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Alipay

It is used to support Alipay payment, real-name authentication, and unified login.

SDK device permission calls: IMEI, IMSI, Android ID, MAC address, hardware serial number, ICCID, SSID, BSSID, sensor information, network type, carrier information, WiFi information, system settings, device brand, device model, operating system.

Link to Alipay’s Privacy Policy:

https://opendocs.alipay.com/open/54/01g6qm

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

QQ

(Tencent)

It is used for QQ quick login.

Get authorization information. Privacy Policy Link: https://privacy.qq.com/document/priview/bdf936b2477a45ff86da57e3d988bc2b

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

AMAP

com.amap.co

(Andriod)

It facilitates input of travel locations and provides functions such as offering discounted flight routes.

Collecting SSID, BSSID, Android ID, GPS location, device MAC address, and base station location information.

Privacy policy link:

https://lbs.amap.com/pages/privacy/

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Ijiami

(Android)

It is used to enhance the security of the Shenzhen Airlines app installation package and prevent it from being decompiled.

No user information is collected.

Do not handle user information.

Baidu Map

It facilitates input of travel locations and provides functions such as offering discounted flight routes.

The SDK will obtain the following information when the app is running in the foreground or background:

Device information: including device identification information (Android ID, IDFA, IDFV), system information (operating system version, device brand and model, device configuration), and application information (application name).

Location information: including latitude and longitude, GNSS information, WiFi address and signal strength information, WiFi status, WiFi parameters, WiFi list, base station ID data information, carrier information, device signal strength information, IP address, Bluetooth information, and sensor information (acceleration, gyroscope, orientation, pressure, rotation vector, light, magnetometer).

Privacy policy link: https://lbsyun.baidu.com/index.php?title=openprivacy

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

YouZan

Hangzhou YouZan Technology Co., Ltd.

It obtains user identification for login and purchase in the official Shenzhen Airlines Shenfen Mall.

 Personal commonly used device information, network information, location information. Specific types of device information include: device identifiers (IMEI, IDFA, Android ID, MAC, OAID, etc.), application information (application crash information, notification switch status, software list, etc.), device parameters and system information (device type, device model, operating system, and hardware-related information).

Privacy policy link:

https://doc.youzanyun.com/resource/develop-guide/35675/40372

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Baidu Analytics

It checks the Shenzhen Airlines app runtime environment by calling msc.baidu.com, enhancing the security of the Shenzhen Airlines app.

No user information is collected. Privacy Policy Link: https://tongji.baidu.com/web/help/article?id=330&type=0

Do not handle user information

Huawei Push Kit

Provide message push service to HuaWei smartphone users to improve delivery rate.

Types of personal information collected include device information, geographic location, and network information. Specific types of device information include device identifiers (IMEI, IDFA, Android ID, MAC, OAID, etc.), application information (application crash information, notification switch status, software list, etc.), device parameters and system information (device type, device model, operating system, and hardware-related information).

 

Privacy policy link:

 

https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/privacy-statement-0000001050042021

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Meizu Push

Provide message push service to MeiZu smartphone users to improve delivery rate.

Types of personal information collected include device information, geographic location, and network information. Specific types of device information include device identifiers (IMEI, IDFA, Android ID, MAC, OAID, etc.), application information (application crash information, notification switch status, software list, etc.), device parameters and system information (device type, device model, operating system, and hardware-related information).

Privacy policy link:

https://www.meizu.com/legal.html

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Vivo VPush

Provide message push service to Vivo smartphone users to improve delivery rate.

Collection of personal information: device information, geographical location, network information. Specific types of device information collected: device identifier (IMEI, IDFA, Android ID, MAC, OAID, and related information), application information (application crash information, notification switch status, software list, and related information), device parameters, and system information (device type, device model, operating system, and hardware-related information).

Vivo Privacy Policy Link: https://dev.vivo.com.cn/documentCenter/doc/366

 

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Xiaomi MiPush

Provide message push service to Xiaomi smartphone users to improve delivery rate.

Collection of personal information: device information, geographical location, network information. Specific types of device information collected: device identifier (IMEI, IDFA, Android ID, MAC, OAID, and related information), application information (application crash information, notification switch status, software list, and related information), device parameters, and system information (device type, device model, operating system, and hardware-related information).

Xiaomi Privacy Policy Link: https://dev.mi.com/console/doc/detail?pId=1822

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

OPPO Push

Provide message push service to OPPO smartphone users to improve delivery rate.

Collection of personal information: device information, geographical location, network information.

Specific types of device information collected: device identifier (IMEI, IDFA, Android ID, MAC, OAID, and related information), application information (application crash information, notification switch status, software list, and related information), device parameters, and system information (device type, device model, operating system, and hardware-related information).

OPPO Privacy Policy Link: https://open.oppomobile.com/wiki/doc#id=10288

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Tencent Browser Service

Load web content within the Shenzhen Airlines app, including Easy Pass benefits (providing a one-stop comprehensive travel solution) and other webpage content.

Collects personal information: device information, network information. Specific types: device identifier (IMEI, IDFA, Android ID, MAC, OAID, and related information), application information (notification switch status, software list, and related information), device parameters, and system information (device type, device model, operating system, and hardware-related information).

Privacy Policy Link: https://privacy.qq.com/document/priview/bdf936b2477a45ff86da57e3d988bc2b

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

JD Pay

It provides JD Pay functionality for payment.

Types of personal information collected: It may collect order-related information, may collect mobile phone number, name, ID number and other information.

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Tencent Mobile Open Platform

Obtain developer services

 

Collect Android ID information.

Information is collected through the SDK, and the SDK provider is responsible for processing the information for the intended purpose to provide corresponding functionality.

Ⅳ. Rules for the Use of Your Personal Information by Shenzhen Airlines

We will use the personal information we collect in accordance with the provisions of this privacy policy and for the purpose of implementing our products and/or services. Please note that all personal information you provide when using our products and/or services, or personal sensitive information collected based on your consent, will be continuously authorized for use during your use of our products and/or services unless you delete or withdraw your consent or refuse our collection through system settings. When you withdraw your consent or cancel your account, we will stop using and delete your personal information.

We will conduct statistical analysis of the use of our products and/or services and may share these statistical information with the public or third parties to show the overall usage trend of our products and/or services. However, these statistical information will not contain any personally identifiable information.

When we display your personal information, we will use content replacement and anonymization to desensitize your information to protect its security.

When we use your personal information for purposes not mentioned in this policy, or when we use information collected for specific purposes for other purposes, we will seek your prior consent through active checkboxes.

Ⅴ. Legal Basis for the Processing of Your Personal Information by Shenzhen Airlines

We will not process your personal information without any legal basis. In general, the legal basis for processing your personal information includes:

Performance of the contract between you and us, such as the General Conditions of Carriage, specific product service agreements, and the PhoenixMiles member handbook.

Compliance with our legal obligations, such as obligations under civil aviation laws and regulations.

Obtaining your consent, such as your consent to receive promotional information from us.

Protecting your or other natural persons' vital interests or carrying out public health emergencies, such as requiring temperature measurement and recording for passengers displaying abnormal temperatures at the boarding gate and reporting to the competent authorities for follow-up.

In the European Union or European Economic Area, processing your personal information for our legitimate interests, including managing your personal information within the information system, improving our products and services, conducting PhoenixMiles member activities, participating in our social activities, conducting anti-fraud measures for transaction security and network information security. Based on this legal basis, you have the right to object to or request limitations on our processing.

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

(Ⅰ)Technology and Measures 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 use industry-standard security measures to protect the personal information you provide to prevent unauthorized access, disclosure, use, modification, damage, or loss of data. For example, we use Transport Layer Security (TLS) encryption technology and strong password algorithms (such as ECDSA key negotiation, AES256 channel encryption, etc.) to ensure the security of transactions during transmission. For stored personal information data, we use industry-standard encryption technology to encrypt the user's personal information for storage. We also use isolation technology for isolation. Access to stored data is logged and saved, and log files are monitored for integrity to ensure that log files are not tampered with. In addition, we perform regular internal and external security scans and penetration tests to ensure the security of production systems.

2.We have obtained the following certifications: Our e-commerce system has passed the third level of the Information System Security Certification in the People's Republic of China, and we have obtained ISO27001 certification and PCIDSS certification.

3.We have appointed a personal information protection officer to oversee our personal information compliance work comprehensively. We have also established a data security officer and working group to promote and ensure data security. We have established an information security management system to regulate the collection, transmission, use, and storage of personal information. We require employees who may access personal information to sign confidentiality agreements and fulfill corresponding confidentiality obligations. Employees receive regular training on information security and personal information protection to enhance their awareness of protecting personal information.

4.The internet is not a completely secure environment, and communication methods such as email are not encrypted. We strongly recommend that you do not send personal information through such means. Please use complex passwords to help us ensure the security of your account.

5.To address the risks of personal information breaches, damage, and loss ("personal information security incidents"), we have established emergency response measures for personal information breaches and personal information security incident response plans, as well as dedicated emergency response teams. We will notify regulatory authorities and/or affected passengers in accordance with applicable laws and regulations in the event of a personal information breach.

(Ⅱ)Storage Period of Your Personal Information

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

Ⅶ. Protection of Personal Information of Minors

1.The age requirement for minors (“child”) who are able to give consent varies in different jurisdictions. If you are a minor under the age of 14 in China or a child in other jurisdictions (such as under 16 years old in the European Union or under 13 years old in the United Kingdom), you should obtain written consent from your parents or legal guardians before using our products or services. Shenzhen Airlines protects the personal information of minors in accordance with relevant laws and regulations.

2.Additionally, we will only process the minimum amount of information necessary within the scope of products and services purchased by children and ensure appropriate security measures are in place. We guarantee that we will not create profiles of children, send them promotional messages, or use their personal information to induce them to engage in activities that are inconsistent with their age and responsibility.

3.In the case of collecting personal information of children with the consent of parents or legal guardians, we will only use or disclose this information in accordance with the law, with the explicit consent of parents or guardians, or when necessary to protect the children.

4.If a child provides personal information to us without the consent of their parents or guardians, the parents or guardians can contact us at dpo@shenzhenair.com to have the information removed or cancel any promotional activities associated with the provided information.

For more specific information on the protection of children's personal information, please refer to the "Shenzhen Airlines Children's Personal Information Protection Rules"

Ⅷ. How is Your Personal Information Transferred Globally

The personal information we collect and generate within the territory of the People's Republic of China is stored within the territory of the People's Republic of China.

For the purposes stated in this privacy policy, your personal information may be transferred to and processed in countries or regions outside of your habitual residence. In such cases, we will protect your personal information in accordance with applicable laws and regulations, and transfer your personal information globally, including but not limited to:

1.If your personal information is transferred outside of the People's Republic of China, we will follow the legal and regulatory requirements to fulfill the necessary legal procedures for lawful and compliant cross-border transfers of personal information. You can click here for detailed information about the outbound data.

2.If your personal information is transferred by Shenzhen Airlines from the European Union to countries or regions for which the European Commission has not made an adequacy decision, we will sign standard contractual clauses approved by the European Commission with the receiving party and take security measures to protect your personal information.

Ⅸ. Your Rights in the Protection of Your Personal Information

You have the following rights:

1. Access, copy, and transfer your personal information

You have the right to access your personal information. Specifically, you can view your personal information through the following methods:

(1)Your account information:

Log in to the Shenzhen Airlines app and click on "Me" in the bottom right corner, then click on the “Name” to view "Basic Information" and "Contact Information". You can also view other personal information in the "Me" section.

Log in to the Shenzhen Airlines official website and click on your personal account in the upper right corner to view your personal information.

Log in to the Shenzhen Airlines WeChat Mini Program and click on "Me" in the bottom right corner to view your personal information.

Log in to the Shenzhen Airlines WeChat Official Account and click on "Me" - "Membership Center" - "Name" to view "Basic Information" and "Contact Information". You can also view other personal information in the "Membership Center" section.

(2)Your membership information:

Log in to the Shenzhen Airlines app and click on "PhoenixMiles" and "Mileage Bills" to view your membership information and mileage.

Log in to the Shenzhen Airlines official website and click on "Personal Information" and "Mileage Bills" to view your membership information and mileage.

Log in to the Shenzhen Airlines WeChat Mini Program and click on "Me - PhoenixMiles" to view your membership information and mileage.

Log in to the Shenzhen Airlines WeChat Official Account and click on "Me - Membership Center - PhoenixMiles Services" to view your membership information and mileage.

(3)Your order information:

Log in to the Shenzhen Airlines app and access "Me - All Orders" to view your order information.

Log in to the Shenzhen Airlines official website and access "Order Management" to view your order information.

Log in to the Shenzhen Airlines WeChat Mini Program and access "Me - My Orders" to view your order information.

Log in to the Shenzhen Airlines WeChat Official Account and access "Me - My Orders" to view your order information.

In addition, you have the right to ask us to provide you with a copy of your personal information that we process. And subject to applicable data protection laws, you also have the right to ask us to transfer your personal information to another processor of personal information designated by you, however, please note, under GDPR if you request to exercise the right to data portability, we will try our best to provide the copy of your data to you per your request, but it is technically hard to port the structured, commonly used and machine-readable formatted data to another controller.

2. Correct and supplement your personal information

If you need to correct or supplement other personal information or request a copy of your personal information processed by us, or request us to directly transmit your information to a third-party company where conditions allow, you can contact us using the contact information under the "How to Contact Us" section.

3. Delete your personal information

You have the right to request the deletion of 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 our processing of personal information violates the agreement between you and us;

(4)If the purpose of our processing has been achieved, cannot be achieved, or is no longer necessary for the processing purpose;

(5)If we cease to provide products or services, or the data retention period has expired;

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

(7)If you personally withdraw your consent;

(8)Other circumstances as provided by laws and administrative regulations.

If the legal and administrative regulations require the retention period to be incomplete or if it is technically difficult to delete personal information, we will stop processing other than storage and take necessary security measures.

4. Cancel your account

you have the right to cancel your registered account with Shenzhen Airlines. After you choose to cancel, we will securely delete or anonymize your personal information.

You can exercise your right of deletion or cancel account by contacting us through the detailed contact information under the "How to Contact Us" section or by using the "Shenzhen Airlines App - Me - Settings - Account Security - Permanent Cancellation of Shenzhen Airlines Account".

5. Agree or refuse to receive promotional information from us

You have the right to choose to consent or refuse to receive promotional activity information from us. You can choose to consent or refuse to receive promotional activity information from us by clicking on "Me - Messages - Settings - Promotional Activities" in the Shenzhen Airlines app.

You can unfollow or unsubscribe to our WeChat Official Account, Weibo, and other official social media platform accounts at any time.

6. Limit or refuse the processing of your personal information

You have the right to refuse our processing of your personal information, request us to restrict the processing of your personal information, request the portability of your personal data, or request an explanation of the rules for processing personal information. You can contact us using the detailed contact information under the "How to Contact Us" section to exercise these rights.

If we collect and process your personal information based on your consent, you have the right to withdraw your consent at any time. You can contact us using the detailed contact information under the "How to Contact Us" section to withdraw your consent. The withdrawal of your consent will not affect the lawfulness of any processing activities that have been carried out based on your consent prior to withdrawal, nor will it affect the lawfulness of processing your personal information based on legal grounds other than your consent.

7. Execute your rights

In order to protect the security of your information, we may ask you to provide a written request or verify your identity, after which we will respond to your rights request within a reasonable period of time as permitted by law. In addition, under the PIPL of China, if you are exercising rights on behalf of another person, or if you, as a close relative of a deceased person, request access, copying, correction, or deletion of the deceased person's relevant information, please provide proof of identity for both yourself and the other person, as well as proof of the relationship, such as a specific power of attorney or a certificate of the deceased's (presumed) death.

We will respond to any requests from individuals to exercise their personal information protection rights in accordance with applicable data protection laws. In general, for requests made through the Chinese app or mini program, we will respond and process requests for access, rectification, deletion, and cancellation within 15 working days. To ensure the security of passenger personal information, we may request relevant verification information to prove your identity. In the European Union or the United Kingdom, we will respond to requests regarding personal data rights within one month. If your request is particularly complex and requires an extension of the response period in accordance with legal requirements, we will notify you promptly in accordance with applicable laws.

You have the right to lodge a complaint or legal action with the regulatory authority or court in your habitual residence or where the incident occurred regarding the exercise of the above rights or our response.

Ⅹ. Updates to this Privacy Policy<

Our privacy policy may change due to changes in laws, technological updates, or practical circumstances.

However, we will not reduce the rights you are entitled to under this privacy policy without your explicit consent. We will publish any changes to this policy on this page. For significant changes affecting your rights, we will also provide more prominent notice, such as providing in-app notifications or sending emails through the Shenzhen Airlines app.

You can view the latest update date of this privacy policy at the top of this privacy policy under "Last Update".

Ⅺ. How to Contact Us

If you have any questions or concerns about our use of your personal information, wish to exercise your rights in the protection of your personal information through this privacy policy, or have any complaints, suggestions, or opinions, please contact us using the following information:

Email: dpo@shenzhenair.com

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