Last updated: 02/08/2023

[AirTrans Technology Co., Ltd] (hereinafter as the “Company”, “we”, “our” or “us”) understands the importance of protecting your privacy. Therefore, we have established a Privacy Policy to explain how the Company treats your information and protects your privacy when you use this software (the “Software”) and services this Software provided (the “Service”) and the rights and options available to you regarding your information. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Any information that we collect is subject to the privacy policy in effect at the time that information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or other notification, and we’ll indicate when those changes will become effective. 

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SOFTWARE AND SERVICES.

**Information the Company Collects and Use **

For the purposes of European data protection laws, the Company is the data controller of your personal information. 

When you use the Software and Services, for analytical, business and operational purposes ,we automatically collect and store the following types of information:

1. **Technical Information.**Certain technical information regarding your device, and your use of the Software and Services and other third party software and applications installed on your device (the “Other Software”), including the type, name and version of operating system and Other Software including, without limitation: (i) their interactions with the Software and Services, your configuration and settings of the Software and Services, version of the Software and Services; (ii)ISP (Internet Service Provider),, anonymous user identifiers, device configuration and identifiers.

  The purposes of the technical information is: (i) to operate and update the Software and Services and provide you with existing and new functionality and features; (ii) to improve and customize the Software and Services; (iii) to provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners; (iv) to maintain and improve the quality and operation of the Software and Services; (v) to notify you of Software and Services updates.

2. **Usage Information.**Certain usage related information regarding your use and interaction with your device, including the Software and Services and Other Software, such as when and how you use the Software and Services; for example, offerings and advertisements that you view, use and access, how you use them and your response to them, how frequently you use them, your search queries and the time and date of your searches.

  The purposes of the usage information is: (i) to improve and customize the Software and Services; (ii) to provide you personalized content, including through the delivery of targeted interest-based advertisements from us or our partners; (iii) to maintain and improve the quality and operation of the Software and Services; (iv) to take any action in case of a dispute involving you in connection with the Software and Services; (v) to enforce the terms and conditions applicable to the Software and Services and to prevent unlawful activities and misuse thereof.

3. **Registration Related Information.**Information you provide when you register

for the Software and Services (if applicable), such as name, e-mail address, password and gender.

The purposes of the registration related information is: (i) to improve and customize the Software and Services; (ii) to maintain and improve the quality and operation of the Software and Services; (iii) to notify you of Software and Services updates; (iv) to provide you with support and handle your complaints and/or feedback.

4. **Support Related Information. **If you communicate with us via our support section or via email, we may also collect your email address, name and any information voluntarily submitted by you in connection with such support (for example, your name, and particular support query or request). Such information will only be used to provide you with support services and will not be connected with any other information collected from you on or through the Software and Services, including, any individual User ID (as defined below) generated or collected by us. 

When you use the Software and Services, we automatically generate an anonymous internal user ID (which does not personally identify you), which is assigned to your use of the Software and Services (the “User ID”) and may be combined with any of the above information.

   The purposes of the support related information is: (i) to take any action in case of a dispute involving you in connection with the Software and Services; (ii) to enforce the terms and conditions applicable to the Software and Services and to prevent unlawful activities and misuse thereof; (iii) to comply and satisfy any applicable law regulation, legal process or enforceable governmental request;(iv) to provide you with support and handle your complaints and/or feedback.

  While it is not our intention to collect any personally identifiable information (“PII”) (except for registration and support purposes as set forth in this Privacy Policy), the data collected may include PII. As part of our privacy measures, we implement certain rules designed to avoid the unintentional collection of PII such as email addresses, social security numbers, credit card numbers etc. Such rules are based on known field types, parameters, values and algorithms but they are not foolproof and hence the Software and Services may sometimes, unintentionally, collect unwanted information. We regularly examine and update these rules.

If you located in EEA, as required by law, you hereby grant your consent to us to use or process your personal information only for the purpose described above once you use the Software or the Service. And you may withdraw your consent at any time. 

**Sharing Information with Third Parties**

We will not share any PII that we have collected from you except for the following events:

1. If we are required by law to disclose your information, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g., to detect, prevent or otherwise address fraud, security, or technical issues; to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of the Company’s users, its partners, or the general public);

2. In the event the Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred;

3. We may share your information with certain third parties (including, without limitation, search engines, content providers, and advertising networks and platforms) that provide various services (such as advertising, marketing, analysis, content, and search) in connection with the Software and Services. We take appropriate measures to ensure that no user can be individually identified from the disclosure of such information, and we require these third parties (i) to keep the data secured, (ii) not to use the data for any other purpose other than to provide us with Services (for example, we use Google Firebase, in addition to our own analytics technology, and other third-party analytics packages to collect, monitor and analyze the information we collect in order to increase our functionality and user-friendliness, to better tailor the Services to our users’ needs, and to understand and analyze how you are using our Services. We also share your information with Google as necessary to receive the Google Firebase service. For more information please see Google’s privacy policy ([http://www.google.com/policies/privacy/][1]) addressing the information that is collected to provide the Google Firebase service and how Google uses such information); and (iii) to use the data solely in compliance with this Privacy Policy. If you want to delete any personal data which we have shared with the third parties, please contact our Data Protection Officer by email at:[air@airtrans.co][3]. We would try our best to notify the third party of deleting the relative personal data, but no warranty as to the deletion is made by us.

4. We may also share PII and non-personally identifiable information with our subsidiaries, affiliated and parent companies but their use of such information must comply with this Privacy Policy. 

**Information may be Collected by Third-Party**

Certain Software and Services may include and/or enable you to add content to them. The content may be in the form of buttons, gadgets, links to third party advertisements, websites, products and services (including search services) as well as additional means that are provided to you by third parties (collectively, “Third Party Content and Services”). The use of such Third Party Content and Services is subject to their privacy policies. You shall be aware that the use of the Third Party Content and Services may give these third parties the ability to access, collect, store, and/or share your information, both your PII and non-personally identifiable information. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Content and Services and your access to any Third Party Content and Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Content and Services. You expressly relieve us from any and all liability arising from your use of such Third Party Content and Services. We recommended that you read the terms, conditions and privacy policies of such Third Party Content and Services before using or accessing any of them.

For providing customized advertisement, the third-party advertising companies may collection or use your personal information (not including your name, address, email address or telephone number) when you use the Software or Service.

**Transfer of Data Outside Your Territory**

The Software and Services work over the Internet. We may store and process your information in various locations throughout the world. Where you located in the EEA, as required by law, you hereby provide us with your express consent to transfer your data to where may be outside of EEA once you use the Software and/or Services. You may withdraw your consent at any time.

**Security of Your Information**

The security of user’s information is our utmost priority, and we take strict measures in order to protect the data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and Network access designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for user’s information. 

We also protect user’s privacy by seeking to minimize the amount of sensitive data and PRI. We also seek appropriate contractual protection from our partners regarding their treatment of user data.

Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

We retain the information we collect as described in this Privacy Policy for as necessary for the provision of the Services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the Services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

**Your Data Rights**

You have the right to access, modify, correct or delete any personal data which we may have collected. 

If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of your personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.

To exercise this right please contact our Data Protection Officer by email at: [air@airtrans.co][3]

**Notices**

If we are required to provide you with notice of a particular event or incident, we will send you such notice by mail, email or telephone.

**Copyright and Trademarks**

All content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and the selection and arrangements thereof are the exclusive property of the Company, or its respective content providers, and are protected by international copyright laws and other applicable laws and regulations. 

All trademarks, service marks and trade names used on the Software or the Service (collectively the “Marks”) are solely owned by the Company.

**Termination of Usage**

Any conduct by a user that in our sole discretion restricts or inhibits any other user from using or enjoying the Software and Service, is prohibited. You agree to use the Software only for lawful purposes and in accordance with that prohibition. You agree that you will not transmit any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including, but not limited to, any material that encourages conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable local, state, national, or international law. The Company may, without incurring any liability to you, terminate access by you or suspend any access to all or part of the Software, without notice, for any conduct that we in its sole discretion, believes is in violation of any applicable law or this Policy, or is harmful to the interests of another user, a third-party, a merchant, a sponsor, a licensor, a service provider, or the Software.

**Contact the Company**

If you have any questions or concerns with respect to any matter covered by this Privacy Policy, you may contact our Data Protection Officer by email at: [air@airtrans.co]