The Privacy Policy

Spring Airlines(or “We” below) fully respects and protects personal information of users. When you use our services, we may collect and use your personal information. We hope to explain relevant important contents to you through this privacy policy(or “this policy” below).

This policy is closely linked with our services that you select. Please carefully read and understand all contents of this policy, so as to help you to make a suitable choice. We try to use clear and concise literal expression and mark articles that may limit your rights or have potential risks in this policy in bold italics, so as to remind you to notice it. The versions in other languages of this policy are only provided for specific customers to read and comprehend. If there is any ambiguity with this simplified Chinese, please refer to this version.

We exactly know the importance of personal information, so we will try our best to protect its safety pursuant to the law. For this reason, we will observe the following principles: parity of authority and responsibility, principle of definite objective, principle of agree, minimum useful rule, principle of ensuring safety, principle of subject participation, and principle of transparency. Meanwhile, we promise that we will take corresponding safety protection measures to protect your personal information in line with mature safety standards in the industry.

If you have any doubt or suggestion, please contact with you through the contact information below.

e-mail: cs@ch.com

Hotline: 95524

 

Latest date updated: August 31, 2018

 

This policy will help you to understand the contents below:

1. Definition

2. Scope of application

3. How to collect personal information

4. How to use personal information

5. How to store personal information

6. How to protect personal information

7. Your rights and personal information management

8. Third-party web link/third-party services

9. Information protection of juveniles

10. Basis and updating of the privacy policy

11. How to contact with us

12. Clauses

 

 

1. Definition

1) Spring Airlines: it refers to Spring Airlines Company Limited, founded pursuant to Chinese law. The business address is located at No.2 Building, Hangyou Hotel, No.2550, Hongqiao Road, Shanghai Municipality. The English name is Spring Airlines Company Limited, for short Spring Airlines. Two-letter designator and three-letter designator of flight are 9C and CQH, respectively. IATA settlement code is 089. Spring Airlines is a public company listed in Shanghai Stock Exchange. The owner or operator of Spring Airlines Platform can control its constituent parts.

2) The affiliated company: it refers to the single term or general term of entity with the association of Spring Airlines

 “Association” means directly or indirectly controlled subjects for any subjects (including individuals, companies, partnership firms, organizations or any other entities), directly or indirectly controls its subjects or subjects directly or indirectly controlled by the same subject.

The aforesaid “control” refers to hold the voting power, contract or other ways, has the power to directly or indirectly instruct relevant subject management and decision-making or other people or even other relations of practical control in fact.

The controlling shareholder of Spring Airlines is Shanghai Spring International Travel Service(Group) Co., Ltd(“ Spring Travel”). Spring Travel and associated entities are affiliated companies of the company. The actual controller of Spring Airlines and Spring Travel is Mr. Wang Zhenghua.

3) Spring Airlines platform: it is controlled by Spring Airlines and its affiliated companies, including online platform(e.g. online pipeline or interactive interface, such as official website, official APP, WeChat official account(H5 and mini program, etc., and official weibo), offline channels(Spring Airlines stores or authorized Spring Authorized stores), as well as all process or scenes that you can contact with Spring Airlines services, such as hotline(95524), e-mail, and man-machine interaction application scenes(various auto-answer systems, CUSS and self-help consignment equipment).

4) Official website: official website of Spring Airlines is: www.ch.com and m.ch.com.

5) Official APP: download address of its official APP is: https://www.ch.com/app-download.html

6) WeChat official account: WeChat official account of Spring Airlines is: springairlines. The account subject is Spring Airlines Company Limited.

7) Equipment: it refers to the device that can be used to access Spring Airline services, (including but not limited to) desk computers, notebooks, tablet PCs, or smartphone and mobile phones.

8) Personal information: it refers to all kinds of information that can be independently recorded in electronics or other modes and can combine with other information to identify individual status of natural person, including but not limit to name of natural person, date of birth, ID card, personal biological recognition information, address and telephone.

9) Personal sensitive information: it means that once it is leaked or illegally provided or abused, it may endanger personal and property safety. Personal reputation and physical & psychological health are easy to suffer from damage or discriminatory treatment. Personal sensitive information contains ID card number, individual biological recognition information, bank account, communication log and contents, property information, credit information, tracking, accommodation information, healthy physiological information, trade information, and personal information of children below 14 years old(including). Personal sensitive information is the core constituent part of personal information. Its connotations or criteria are adjusted with the adjustment of applicable law.

10) China: It refers to the People’s Republic of China. It only aims to provide convenience for this document, so it excludes Hong Kong Special Administrative Region, Macao Special Administrative Region and Taiwan

11) Applicable law: This policy is based on Chinese laws, which include Cyber-Safety Act and Information Security Technology—Personal Information Security Specification, and policy issued by Civil Aviation Administration of China. And this policy refers to GDPR of European Union(EU).

12) GDPR: It refers to General Data Protection Regulation, which was released by EU and took effect on May 25, 2018.

13) DPO: It refers to Data Protection Officer. The data protection officer of the company takes charge of supervising compliance situation, provides notification and suggestion on our data protection obligation and acts as the linkman of you or any regulatory authority of personal data protection on behalf of the company.

 

2. Scope of application

This policy is suitable for users who use our services(no differentiation between members and non-members). For example, if you order our tickets on Spring Airlines Platform, take our plane or accept other services, we think that you agree to accept constraint of this policy.

If you delegate an agent to purchase and accept our services, we think you agree to accept constraint of this policy in default. If you or your agent purchase our services on non-Spring Airline platform or unauthorized third-party platforms, we will not undertake any responsibility for any personal information leakage and relevant risks.

If our affiliated companies(e.g. Shanghai Chunhua Aviation Ground Service Co., Ltd, which is our agent of ground services in Shanghai airport region) provide relevant services for you without signing the independent service agreement, this policy is also suitable for an affiliated and related services.

When this policy has a conflict with legal provisions of judicial region that can administer services, this policy shall remain completeness and validity in the maximum allowable range of local laws unless final judicial decision thinks it is invalid.

 

 

3. How to collect personal information

Ø  Purposes of information collection

 (1) The purpose of collecting personal information is to fulfill the contract and observe legal obligations. (2) If we use your personal information in other unlisted purposes of this policy or use the information collected for specific purposes to other objectives, we will ask for your explicit consent or authorization in advance.

Ø  Information collection method

In order to provide the better services for you, you need to agree us to collect the following information:

 (1) Information provided by users

Generally speaking, you have no need to input any personal information to access this website. However, in some pages, we will require you to input personal information, so that we will provide services or carry on transactions according to your requirements. We don’t require you provide the specific personal information. However, without the information, it is impossible for us to provide services or carry on transactions for you as required. For example, when you book a ticket, you at least shall provide name of airplane passengers, identification type, ID number, name of contact person, telephone and e-mail, so that we can offer flight ticket booking, information notification and subsequent ticket refunding and changing.

 

(2) Information collected automatically

We will collect information relating to website access, including page browsed, number of bytes passed, links clicked, materials accessed, and other operation executed in this website. When you use user ID to enter into the site, it is possible for us to link it with your identity, so as to determine which services followed. If we combine non-personal information with other information for identifying the status of specific natural person or combine it with personal information, the non-personal information will be treated as personal information during the period of combined utilization unless you authorize or there are other stipulations of laws and regulations. We will carry out specialized treatment for the personal information, ensuring safety of personal information.

Attention please, information that we collect automatically also contains your IP address, equipment mode, only equipment identification number, browser model, extensive geographical position (e.g. national or urban level position), as well as other technical information. We are possible to collect information that how your equipment can interact with our website, including pages accessed and links clicked.

 (3) Information provided by third party

The precondition that we gain information from third party is your approval or third party is required by law or we are allowed to legally use your information. We promise that we will use information gained from third party in the legal, rightful and necessary range, observe relevant and necessary information of limited treatment, and ensure accuracy and confidentiality.

 (4) You fully know and agree us to collect and use your information in the following situations without your approval:

a) About national safety and national defense security;

b) About public safety, public health and major public interest;

c) Relating to criminal investigation, prosecution, judgment and execution of judgment;

d) Major legitimate interest for safeguarding you or other users’ life and property, but difficulty in getting your approval;

e) Personal information collected is disclosed by you to the public;

f) Your personal information collected from legal public disclosure;

g) Required by signing a contract according to your requirements;

h) Required by safe stable operation of services for maintenance, such as discover and deal with service faults;

i) Required by legal news reports;

j) Required by statistics or academic research of institutions for academic research based on public interest; as providing academic research or results described, personal information contained in results is conducted de-identification treatment;

k) Other situations stipulated by laws and regulations.

(5) If you are confused at our collection method of personal information, please inform us.

Ø  Information collection type

 (1) Personal information collected by the above method includes:

a) Detailed contact information, such as your name, e-mail, telephone, fax number and contact address, etc;

b) Detailed personal information, such as gender, date of birth, nation, nationality and country of residence, etc;

c) Biological recognition information, such as personal gene, facial recognition features, fingerprints and iris, etc; 

d) Personal identification, such as ID card, passport, certificate of officers, certificate of the disabled, and driving license, etc;

e) Network identity label information, such as Spring Airlines account, IP address, e-mail address, password relating to aforesaid contents, password, and password protection answer, etc;

f) Personal internet recording, such as browsing history of Spring Airlines website, software use recording, and click recording etc;

g) Personal financial information, such as credit card or account information, regular member and green wing member information;

h) Your preference to receive our market propaganda e-mail;

i) Information that is good for us to determine the most satisfactory products and services;

j) Activity registration information; your overall feedback on our website, products and services.

 (2) We will try to apply reasonable and feasible technical measures and avoid from collecting personal information that is irrelevant of your services.

 (3) If you are confused at personal information type collected, please inform us.

4. How to use personal information

 (1) Your personal information will be used for the following occasions:

a) Preparation, provision and summary for conventional passenger services of inquiry, reservation, ticket sales, boarding, airport services and cabin services, special passenger services of wheelchair users and babies(conventional passenger services and special passenger services are called as basic services or necessary services); necessary services are provided by Spring Airlines, but some process(e.g. airport check) may need participation of third-party service providers or shall be provided directly for legal, technical or commercial limitation;

b) Sales and performance of unnecessary services(or additional services or value-added services) provided by Spring Airline, including seat selection in advance, extra luggage, and passenger cabin catering relating to air transport services gifted by Spring Airlines or selected by passengers, sales and performance of unnecessary services provided by third party(unnecessary services or third-party services), including airport pickup and drop-off, VIP services, WIFI access, onboard retailing, accommodation, tourism products; providers of unnecessary services based on correlation strength of basic services may be third party designated by Spring Airlines and relevant service contracts or temporarily arranged third party.

c) Above services provided by visa transfer, aircraft lease, code sharing or multimodal transport;

d) Guide, supply and manage other services provided by Spring Airlines;

e) Operation attached by items (a)-(d) or related operation;

f) Implementation of investigation relating to services provided by Spring Airlines;

g) Sales analysis, investigation study or development of new services;

h) Service notification provided by Spring Airlines;

i) Information of various services, products, projects and propaganda activities provided by Spring Airlines, its parent company, subsidiaries and other partners;

j) Response for inquiry and requirements

 (2) Information use mode

Ø  Information sharing

In order to provide services for you based on Spring Airlines platform conveniently, we recommend information in which you are interested or we will protect personal property safety of affiliated companies of Spring Airlines or other users or the public from being damaged. Your personal information may be shared with our affiliated companies. We promise that we only share necessary personal information and it is constrained by objectives stated in this privacy policy. If we share personal sensitive information or affiliated companies change personal information use and treatment objectives, we will ask for your authorization and approval in the form of the remarkable reminder.

Ø  Information transfer

We won’t transfer your personal information to any organization, company and individual unless the following circumstances or objectives.

a) Get approval of users;

b) Provide pursuant to laws and regulations, legal procedures, compulsory judicial or administrative requirements;

c) As getting involved in consolidation, purchase, asset transfer or similar transaction, if it is involved in personal information transfer, we will require the company and organization that hold your personal information to be constrained by this privacy policy. Otherwise, we will require the company and organization to ask for your authorization and approval again.

Ø  Business delegation

We are possible to delegate our business activities to third party, so as to provide some services for you or fulfill functions on behalf of us. Under the circumstance, users’ personal information is likely to be revealed to third party. Under the circumstances, we will only reveal your personal information to third party for legal, rightful, necessary, specific and definite objectives. We will take the suitable measures with the third party, so as to safeguard confidentiality and security of client data, including establish the treatment agreement for the personal information and ensure that third party won’t use the information for any other objectives.

Third party includes but not limit to:


1

Affiliated   companies of Spring Airlines

2

In terms of   Spring Airlines business, any agents,   subcontractors or third-party   service providers of providing administration,   promotion and study,   distribution, data treatment, telephone promotion,   telecommunications,   computers, payment or other services

3

Other business   partners, such as air carriers,   land or marine transport operators,   loyal plan operators, and other companies   that provide customer   services or fulfill customer requirements

4

Credit data   service institutions

5

Companies and/or   banks of credit cards, deduction   cards or charge cards

6

Government or   non-government agencies, agencies   or supervision organizations

7

Medical   professionals, insurance companies and   clinics/hospitals 

8

Third party   delegated and authorized by Spring   Airlines based on judgment of legal   rules

 

5. How to store personal information

 (1) In principle, personal information collected and generated within the territory of China will be stored in the territory of China. Information collected from overseas is possible to be stored in the territory of China. When laws of information collection site have a conflict with our storage policy, please inform us in time, so that we will respond your appeal in time and avoid from causing unnecessary trouble for your personal information protection.

We promise that we only store your personal information in the storage during the required period of objectives and time limit stipulated by laws and supervision regulations in this policy. We neither reserve your personal information exceeding the required time to deal with objectives nor reserve necessary time with the collection objective of data reservation policy unless retention period is lengthened or it is allowed by law.

Special tips: users’ personal information will be stored in line with rules below:

 

Treatment   objectives

Material types

Retention period  

Deal with   reserve seats/book tourism services for   users

Personal   information 
    Contact information 
    Financial information 

Trip details

Market   investigation information

Save materials   as providing products/services for   users and contract fulfillment in   the allowable period of law

Push marketing   advertising to users

Personal   information 
    Contact information

24 months or   maximum allowable deadline of   applicable laws and regulations

Establish   exclusive trip information for users

Personal   information

Contact   information

Trip details

Market   investigation information

12 months or   maximum allowable deadline of   applicable laws and regulations

 

 (2) Cross-border transfer

Since our services or third-party services required may be cross-border, it means that after getting your authorization and approval or under some special situations allowed by this policy, your personal information may be transferred to the overseas jurisdiction of the country/region where you use relevant services or accept access from the jurisdiction. When our services are involved in cross border and we need to transfer relevant personal information collected in territory to an overseas agency, we will execute it in accordance with laws and supervision regulations and require the overseas agency to keep secret for your personal information by signing an agreement and checking on the spot.

The jurisdiction may be equipped with different data protection act or even has no relevant laws. Under the circumstance, we will ensure that your personal information will receive the sufficiently equal protection within the territory of China. For example, we will require you to approve cross-border transfer of personal information or implement data de-identification before transferring overseas data.

 

6. How to protect personal information

 (1)We will properly manage and protect your personal information, adopt reasonable and feasible safety protection measures that conform to industrial standards to protect your personal information safety, and prudently prevent your personal information from unauthorized access, leakage, utilization, manipulation, damage or loss. You also need to properly registration account and password. We think the operation with your account and password is operated by yourselves in default. 
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(2) After personal information safety event happens unfortunately, we will inform you in time according to laws and regulations: including basic information and possible influences of the safety event, disposal measures adopted or disposal measures to be used, suggestion of your autonomous prevention and risk reduction, and remedial measures for you. We will inform you about relevant event situations by e-mail, letter, telephone and push. When it is hard to inform personal information subjects one by one, we will take reasonable and effective method to announce. Meanwhile, we will report disposal situation of personal information safety events according to supervision department requirements.

7. Your rights and personal information management

 (1) You rights:

a) Right to know: When we collect and gain your personal information, we will provide relevant approach, so that you will know about our status, our objective and mode for personal information treatment, and right maintenance approach.

b) Access right: You have the right to confirm whether your personal information is dealt and know about treatment purposes and retention time.

c) Right of correction: You are entitled to require us not to delay to correct inaccurate data relating to your personal information.

d) Right to delete: you have the right to require us not delay to delete relevant personal information and we have the obligation not to delay to delete your personal information under the specific situations. Attention please, based on special laws and policy of Civil Aviation Administration of China, complaint recording of irregular flight in Normal Management Regulations of Flights shall be saved for 2 years. Under the specific circumstance, maybe we can’t realize this right.

e) Right to limit disposition: Under the specific circumstance, you have the right to limit us to deal with your personal information(For example, if you have any doubt on accuracy of personal information, you can give us some time to check accuracy of personal information).

f) Carrying right: Under the precondition allowed by law, you can require us to transfer your personal information to third party, while we shall try to coordinate with your requirements in the reasonable range. Attention please, under the precondition of technical support and realization of requirements in the current situation, we can coordinate with you to exert this right.

g) Right to resistance: You have the right to reject us to deal with your personal information with right reason.

h) Automatic decision-making power: You have the right to determine not to be constrained by our automatic treatment behavior.

 (2) Personal information management

a) Access your personal information

Membership information: If you hope to visit or edit personal data information and payment information in Spring Airlines membership account, modification of login password, modification of binding telephone or logout, you can operate it in “mines” of Spring Airlines mobile client or “my Spring Airlines” in Spring Airlines official website.

Order information: You can look up your order recording and trading record in “mines” of Spring Airlines mobile client and “my order” in Spring Airlines official website.

If you can’t access your personal information through the path above, you can contact with us by phone 95524. We will reply your access request within 30days.

b) Correct your personal information

When you find that your personal information is wrong, you have the right to require us to supplement or perfect it. You can propose the application for correction or supplementation by phone 95524. We will coordinate with your rightful request through evaluation meeting.

c) Delete your personal information

Ø  You can propose the request for deleting personal information in the following situations:

i. If our behavior of dealing with personal information violates laws and regulations;

ii. If we collect and use your personal information without your definite approval;

iii. If our behavior of dealing your personal information severely violates the appointment with you;

iv. If you don’t use our products or services or you actively cancel the account;

v. If you don’t provide products or services for you perpetually.

Ø  You can delete partial or full information through the mode below, including cancellation of member account and deletion of non-member information. You need to send an e-mail to Spring Airlines e-mail (e-mail: cs@ch.com, e-mail name: cancellation of member account/deletion of non-member information). You need to note your objectives in the e-mail and provide relevant materials.

A. If Spring Airlines members cancel the account, they need to provide:

i. A picture that members hold a certificate;

ii. Member account;

iii. Telephone or e-mail in registration

B. If non members delete information, they shall provide:

i. A picture that an airplane passenger holds a certificate; and all identification photos to be deleted;

ii. The last recording that an airplane passenger takes a plane, including order number, leg, flight date, passenger name, certificate number, and contact information as booking tickets

Ø  If we determine to respond your request for deletion, we will try out best to gain the third party that gains your personal information and we will require the third party to delete it in time unless there are other stipulations in laws and regulations or your independent authorization is gained from the third party. After you delete the information from our services, we may not delete the corresponding information from the backup system immediately, but we will delete the information in backup updating. After you actively cancel the account, we will stop providing products or services for you and delete your personal information according to applicable law or do anonymous treatment.

d) Alter the range that you approve

Each business function that we provide needs some basic personal information to be completed. Besides, for collection and utilization of extra personal information, you can contact with us by phone 95524 to give or take back your authorization. After you take back the authorization, we will not treat with the corresponding personal information. However, the decision that you take back authorization won’t affect personal information treatment based on your authorization.

e) Request for transferring personal information

When you hope to transfer your personal information to third party, you can file an application for us through 95524. We will refer to allowable law and feasible technical foundation to evaluate and coordinate with you for operation. Please notice the possible risks and expenses of this operation.

f) Request of refusing our treatment

When you determine to refuse relevant treatment activities for your personal information with right reason stipulated by laws and regulations, you can file an application for us through 95524. We will audit it and coordinate with you for operation.

g) Automatic decision of the constrained system

In some business functions, we only can make a decision in accordance with non-artificial automatic decision-making mechanism, including information system and algorithm. If the decision significantly affects you legitimate interest, you have the right to require us to explain it. We will provide the appeal method under the precondition of not damaging business secret of Spring Airlines or other users’ rights and public interest.

h) Request of responding your treatment

Based on the above mode of managing your personal information, in order to greatly respond your treatment requirements, we need you to provide the written requirement or prove your status in other form(of course, we will protect and reasonably store information that you provide). Based on status verification and confirmation of requirements, we will reasonably treat with your request. Meanwhile, we retain the right to refuse treating with the corresponding request. Attention please, you shall fully know about possible risks based on your requirements. Meantime, we will charge some costs in line with physical truth.

8. Third-party website links/ third-party services

Spring Airlines platform may contain the third-party website links or independent third-party services.

In order to make the links clearly and availably, when you click links, your browser will open a new window for links. In general, we will provide reminder for skipping(you will leave the official website of Spring Airlines or similar wording). For your better service experience, independent third-party services may be contained in the website of the company(or column or channel) under some situations, but it will remind in the header or end of the page that third-party service providers undertake responsibilities(display differs from the name of operation subjects or copyright owners in Spring Airlines or reminder “services provided by someone” or powered by someone/ services provided by someone or similar wording). We suggest that you shall carefully read information of each third-party website link and third-party service provider.

Attention please, these third-party website links or third-party services are owned or operated by other companies or organizations. When you use a third-party link or services of a third-party service provider, you provide personal information for it. Your information shall be suitable for the privacy policy or similar statement of the third party or the third-party service provider. We will not undertake any legal responsibilities for any third party’s improper use or disclosure for your information. Risks generated by accessing and using these third-party website links or third-party services shall be totally undertaken by yourselves.

9. Information protection of juveniles

 (1) Spring Airlines pays more attention to personal information protection of juveniles. If you are juveniles below 18 years old(If definition of juveniles in local laws is different or is changed, we will try to observe it; if you have any confusion, please inform us in time). Before using our services, please gain the written consent of your parents or statutory guardian. Spring Airlines will protect personal information of juveniles in line with stipulations in national laws and regulations.

 (2) For the situation of collecting personal information of juveniles collected under the approval of parents or statutory guardian, we will only use or disclose the information under the necessary situations of allow laws, definite consent of parents or guardian or protection of juveniles.

 (3) If we find that personal information of juveniles under the situation without gaining the consent of parents or statutory guardian in advance, we will try all means to delete relevant data as soon as possible.

 (4) If you are parents or guardian of juveniles, when you have any doubt at personal information treatment of juveniles, you can contact with us by phone 95524.

10. Basis and updating of the privacy policy

 (1) Basis

This policy is based on the General Rules of Civil Law, Law on Protection of the Rights and Interests of Consumers, Cyber-Safety Act, and Personal Information Security Specification of Information Safety Technology, policy documents or recommended guide issued by network information office, MIIT and Civil Aviation Administration of China. Also, this policy refers to stipulations of GDPR and other laws, regulations and documents to modify and perfect correspondingly.

 (2) Updating

In the allowable range of laws and regulations, Spring Airlines will modify rights of the privacy policy in line with physical truth. The latest version of the privacy policy will be issued on the official website of Spring Airlines. Meanwhile, date of updating will be issued, so that you will know about the latest privacy policy. Under the circumstance, if you continue using our services, we think that you agree to accept the constraint of the modified policy.

We promise: we will not limit or reduce the right enjoyed by referring to this policy without your definite authorization (including the agreement authorization between both parties) unless changes of compulsory stipulations in laws and regulations require for it.

For major changes, we will provide more significant notification(including some services, we will issue the notification by e-mail to state specific alternation contents of the privacy policy).

Except for applicable laws and regulations or supervision department changes, the “major changes” in this policy also include (but not limited to):

a) Our service types/modes are greatly changed, such as objectives of personal information treatment, types of dealing with personal information and use mode of personal information, etc;

b) We greatly change in ownership structure and organizational framework, such as ownership alternation of business adjustment, bankruptcy and M&A, etc;

c) Personal information sharing and main objects disclosed to third-party information are changed;

d) Your rights in personal information treatment and exercise style are greatly changed;

e) Responsible department for dealing with personal information safety, contact information, and complaint channel are changed;

f) Influence evaluation reports of personal information safety show the existence of high risks.

We will file the previous privacy policy for you to look it up.

11. How to contact with us

(1) If you have any doubt, opinions or suggestion on relevant affairs of this policy or your personal information, please contact with us by e-mail cs@ch.com or by phone 95524

 (2) In general, we will reply you within 30days. If you are not satisfied with the reply or think our personal information treatment mode damages your legitimate interest, you can complain or report to network information office, public security bureau or MIIT.

 (3) The above arrangement will not arrange you to file a lawsuit to the people’s court with the jurisdiction in Changning District of Shanghai, so as to look for solutions.

 (4) Data protection officer(DPO)

e-mail: DPO@ch.com

Address: 4th Floor, No.3 Building, Hangyou Hotel, No.528, Konggang No.1 Road, Changning District, Shanghai Municipality, China

Postal code: 200335

12. Clauses

Under the circumstance that users accept any service of Spring Airlines, the constituent part of the service agreement relationship in this policy(verbal, written or other modes) shall be considered with other relevant service agreements. Under the circumstance, clauses of this privacy policy shall be applicable in priority unless relevant service agreements definitely exclude its applicability.

If personal information is unfortunately leaked for objective causes, including legal requirements for Spring Airlines, force majeure and technical restriction, Spring Airlines shall not bear any liability for loss suffered by users. Under the circumstance with definite third party of imputation, Spring Airlines will assist users to investigate and affix responsibility for the third party. If Spring Airlines violate the legal requirements, the company or relevant person liable shall undertake all legal responsibilities pursuant to the law, including possible administrative punishment or even criminal liability. However, under any circumstance that law does not forbid in the occurrence of claim for compensation, the liability for damage of Spring Airlines for loss suffered by user for personal information leakage shall be limited by compensating for practical loss of users in terms of claim appointed by this policy and relevant service agreement(any unverified or unapproved loss or unreasonable expenses or expenditures shall not be identified as the practical loss) and also can’t exceed double service charge received by Spring Airlines in practice unless it proves that Spring Airlines violates the mandatory provisions or cause a loss with deliberate or culpable negligence. Under the circumstance of failing to distinguish from specific services or Spring Airlines does not charge services, Spring Airlines at least needs to compensate RMB 1000 for the single complaint/claim event. The above promise for compensation is based on the hypothesis that users are blameless. If users have fault in loss, responsibilities of Spring Airline shall be correspondingly alleviated or exempted. In order to avoid from disputes, if users fail to timely inform Spring Airlines or take other reasonably expected measures to stop loss, Spring Airlines has the right to propose to keep from bearing the liability for any subsequent expanded loss. Spring Airlines won’t compensate for pure users’ mental impairment promise.

All disputes caused by validity, explanation and applicability of the privacy policy are suitable for Chinese laws and accept the exclusive lawsuit jurisdiction of the court with jurisdiction in the domicile of Spring Airlines—Changning District, Shanghai Municipality. “Chinese laws” exclude any law or a part that enables substantial law beyond China to be applicable in the maximum allowable range of law.

Validity of Article 12 will not be abandoned for personal expression of any employee or agent unless judicial final judgment affirms it.