Rules on the Protection of Children's Personal Information and Instructions for Guardians of Shandong Airlines

Shandong Airlines Co., Ltd. (hereinafter referred to as "We" or “Us” in short) is well aware of the importance of personal privacy and the protection of children's (hereinafter referred to minors under the age of fourteen) personal information security and privacy. On the basis of the Privacy Rules of Shandong Airlines and the Rules for the Protection of Sensitive Personal Information, we issue these Rules on the Protection of Children's Personal Information and Instructions for Guardians of Shandong Airlines (hereinafter referred to as "this Policy") to explain the rules we follow when we collect and use children's personal information and other related matters. As a parent or guardian of your child or children (hereinafter referred to as "Guardian"), before you or your child or children use the products and services of Shandong Airlines (as defined in the Privacy Rules of Shandong Airlines, hereinafter referred to as "Our Products and Services"), please read through and understand this Policy, especially the terms marked in bold, and ensure that you fully understand and agree to all the terms.

Notes for guardians:

Your understanding and cooperation are necessary for us to protect your child's or children’s personal information and privacy. In order to safeguard your child's or children’s legitimate rights and interests, please ensure that your child or children use(s) our products and services and submit(s) personal information to us under your consent and guidance. We will take special measures to protect your child's or children’s personal information to which we have access in accordance with this Policy. Ask your child or children to stop accessing/using our products and services immediately if you disagree with this Policy.

Notes for children:

Any child should participate in online activities with the prior consent of the guardian(s). If you are a child, please be sure to read this Policy with your guardian, and use our products and services and submit personal information with the consent and guidance of your guardian(s).

This Policy applies to our collection, storage, use, transfer, sharing and disclosure of children's personal information. This Policy serves as a special rule developed on the basis of the Privacy Rules of Shandong Airlines and Rules for the Protection of Sensitive Personal Information. If there is any inconsistency with the Privacy Rules of Shandong Airlines and Rules for the Protection of Sensitive Personal Information, this Policy shall prevail; and any matters not covered herein shall be subject to the Privacy Rules of Shandong Airlines and Rules for the Protection of Sensitive Personal Information.

If you have any questions about this Policy or matters related to this Policy after reading this Policy, you may contact us through the contact information listed in the "Contact Us" section hereof, and we will get back to you as soon as possible.

1. Definition: The terms "Children or Child" used in these rules refer(s) to minors under the age of fourteen.

2. How we collect children's personal information

When you or your children use the products and/or services we provide, we may collect some children's personal information from you or under your supervision. Below, we will explain the types of information whose collection requires your consent and purpose and the consequences of refusing to agree in view of specific services.

 (1) Tickets booking service

To book a ticket for your children, you need to provide the following information about your children: name, gender, nationality, date of birth, type of valid identity document, ID number, expiry date and issuing country.

 (2) Passenger and baggage transportation services

Please make sure you reserve enough time to check in to ensure a smooth journey for you and your child. When you check in at the airport, we will check your child's valid identity card to confirm whether it is consistent with the information you leave when purchasing the ticket.

If you choose our self-check-in service, you should log in to your account in advance or provide the ticket number of you and your child or the identity card number when booking the ticket and your child's name in the non-login state. During check-in, you may be required to provide or verify your child's identity card information, including name, gender, nationality, date of birth, identity card number, expiry date and issuing country. 

In addition, we may also collect your and your child's identity information (including identity documents, household registration booklet), contact information (including mobile phone numbers, e-mail addresses), addresses and other information necessary for judging the guardianship relationship to verify the guardianship relationship.

Failure to provide the above information may prevent your child from using the relevant services provided by Shandong Airlines. The services we provide in relation to children are subject to update and development from time to time. If you choose other services not covered by the Privacy Rules of Shandong Airlines or these rules, and we need to collect children's information to provide such services, we will separately explain the scope, purpose and use of information collection through page prompts, interactive processes, agreements, etc., and obtain your consent.

3. How we use children's personal information

We use children's personal information in strict accordance with relevant laws and regulations and the purposes described in these rules in order to provide and optimize Shandong Airlines’ products and/or services and protect children's privacy.

Your consent will be separately solicited if we intend to use children's personal information for other purposes not specified in these rules or collect additional children's personal information not mentioned in these rules.

4. How we store children's personal information

a) Generally, the personal information we collect in China (including children's personal information) will be stored in China. However, in terms of cross-border business requiring transferring personal information we collect in China (including children's personal information) to overseas institutions, we will ensure adequate protection of personal information (including children's personal information) in accordance with the provisions of effective and applicable laws and regulations and the requirements of relevant regulatory authorities.

b) Generally, we will only store children's personal information for a period necessary for the purposes described herein or required by laws and regulations and will, after the aforementioned period, will delete the personal information of children in accordance with the requirements of laws and regulations.

c) We will stop collecting children's personal information in time after we terminate the service or operation. In addition, we will notify the guardian in advance and delete the children's personal information after terminating the service or operation according to requirements of relevant laws and regulations, unless otherwise specified by laws and regulations or regulatory authorities.

For general terms of Shandong Airlines' storage of personal information and cross-border transfer of personal information, please refer to Section 4 "How We Protect and Save Your Personal Information" of the Privacy Policy of Shandong Airlines.

5. How we ensure the security of children's personal information

a) In order to protect children's privacy and security, we will take reasonable and necessary measures to protect children's personal information in accordance with relevant laws and regulations to reduce the risk of loss, misuse, unauthorized access to, disclosure and modification of such information.

b) We have special management systems, processes and organizations in place to ensure information security so as to strictly control the access to children's personal information and ensure children's privacy. Only the staff of Shandong Airlines who need to know the personal information of the children is allowed to access the personal information of the children.

c) In the event of such security incident as the disclosure of children's personal information, we will activate emergency plans to prevent the escalation of security incidents, and promptly notify by announcements, push notifications or emails children and their guardians of the basic situation of security incidents, actions and remedies we are about to take or have taken and our recommendations for responding. We will promptly notify the progress of the event through App push notifications, sending emails or messages to mailboxes / mobile phone numbers of guardians. If it is difficult to inform one by one, we will issue warnings through announcements and other reasonable and effective ways. We will also actively report the disposal progress of children's information security incidents at the request of regulatory authorities.

For Shandong Airlines' general security measures for personal information, please refer to Section 4 "How We Protect and Save Your Personal Information" of the Privacy Policy of Shandong Airlines.

6. How should you manage children's personal information

 (1) Withdrawal of children's personal information

You have the right to contact us through the contact information provided herein to request the withdrawal of your consent to deal with children's personal information and we will deal with it in accordance with relevant laws and regulations, provide that the legitimacy of our handling of children's personal information will not be affected until such consent is formally withdrawn. Please note that upon your withdrawal of your consent, your child may not be able to continue to use the products and/or services we provide.

 (2) Correction, deletion or cancellation of children's personal information

For your or your child’s more convenient access to and management of your child's personal information during the use of our products and services, and to ensure the rights to correct, delete or cancel the account and other personal information, you and your child may follow Section 5 "Your Rights" of the Privacy Policy of Shandong Airlines or contact us directly through the contact details in this Policy.

If our products and/or services are terminated, we will immediately stop the collection and use of children's personal information in accordance with relevant laws and regulations, and delete the children's personal information involved.

 (3) The right to portability of personal information

If you request to transfer your child's personal information to the designated personal information processor, please contact us through the contact information provided herein.

7. Provide child's personal information to a third party for processing

We will only provide children's personal information to third parties for legal, legitimate, necessary, specific and clear purposes with your authorization and separate consent, and will only provide children's personal information necessary for products and/or services. We will also assess the legality, legitimacy and necessity of providing children's personal information to the third party, as well as the impact on children's rights and interests. If it is necessary to entrust a third party to deal with it, we will take compliance measures in accordance with laws and regulations, including but not limited to, carrying out a safety assessment on the third party, signing an entrustment agreement with the third party, etc.

With the exception of the following circumstances: At the request of laws, regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose the required type of your and your children’s personal information in the required manner. We will require corresponding legal documents, such as subpoenas or investigation letters, if permitted by laws and regulations, when we receive the above-mentioned request for information disclosure. We believe in being as transparent as possible about the information we are asked to provide to the extent permitted by law. All requests are carefully reviewed to ensure their legitimacy and are limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes. For the Shandong Airlines' general terms and conditions of personal information handling, please refer to Section 3 "How We Share, Transfer and Publicly Disclose Your Personal Information" in the "Privacy Policy" of Shandong Airlines.

8. Application and update

These rules may be revised from time to time according to the updates of our products and services and the relevant requirements of laws and regulations. We will inform you of any updates through our official website, Shandong Airlines’ Zhangshangfei APP and other channels, which will take effect after the announcement and replace the previous relevant content.

If any rules hereof are updated, the Zhangshangfei APP of Shandong Airlines will prompt you to confirm and agree to the updated rules on the login page. If you disagree with the updated content, you should immediately stop using the corresponding services; continuing to use the products or services by you and your children provided by Shandong Airlines shall be deemed that you have accepted the updated contents of these rules.

9. Contact Us

If you or your children have any questions about this Policy, or have any complaints or opinions on the disposal of children's personal information, you may contact us through the following channels:

Shandong Airlines customer service hotline: 95369, email: b2czb@sda.cn