Privacy Policy

• Last updated: September 30, 2022
• We understand your information is a big responsibility and work hard to protect your information and put you in control. VariFlight Privacy Policy (hereinafter refer to as the “Policy”) made by VariFlight service provider (hereinafter refer to as “We”) is meant to help you understand:
• I.What Information We Collect and How We Use Information
• II.How We Save and Protect Your Personal Information
• III.How We Share, Transfer and Disclose Your Personal Information
• IV.IV.Your Rights
• V.Protection of Minors
• VI.How Your Personal Information is Transferred Globally
• VII.Use of Cookies
• VIII.Changes to the Privacy Policy
• IX.Contact Us
• If you are a user located in the European Union, please read The Appendix for EU Users. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the contact information of Article 9.
• I.What Information We Collect and How We Use Information
• 1.1When you subscribe to VariFlight e-magazine service, you will provide your name, email address, company information and mobile phone number to optimize our service to you. Mobile phone numbers are considered to be sensitive information, if you do not provide such information, you may not be able to subscribe properly.
• 1.2When you use specifics services, you will provide your email account to log-in and account verification. Email Accounts are considered to be sensitive information, if you do not provide such information, you may not be able to use some services properly.
• 1.3When you apply to be a volunteer, in order to help us determine if you are qualified to be a volunteer, you will provide your full name, nationality, mobile phone number, e-mail address, referee and address, etc. if you do not provide such information, you may not be able to submit applications.
• 1.4When you submit applications using the application collaboration function, you will provide your name, company information, e-mail address, mobile phone number and specific cooperation intention. Providing the above information is a necessary condition for applying, if you do not provide such information, we may not be able to understand your cooperation needs and get in touch with you timely.
• 1.5When you use some of the upgrade features, you will provide your name, company information and job information. As such, the collection of above information is to provide the corresponding upgrade information service after confirming the identity of the user. Such information is sensitive information, refusing to provide such information may result in you being unable to use the above function, but does not affect your normal use of other functions in our website.
• 1.6We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.
• II.How We Save and Protect Your Personal Information
• 2.1The Duration Storing Information
• 2.1.1We will store your personal data until the stated purpose of the cost policy, or until you make a request for deletion - whichever comes first. Except as otherwise provided by relevant laws. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, or operational retention needs.
• 2.1.2In the event where we cease our products or services, we will notify you in the form of push notifications, announcements, etc., and delete your personal information or anonymize such information within a reasonable period of time.
• 2.2Where Information is Stored. We will store your personal information within the territory of PRC. If your personal information needed be internationally transferred, we will ask for your authorization and consent separately.
• 2.3Security Measure
• 2.3.1We shall collect, use, reserve and transmit user information under the principle of "minimization", and inform you of the purpose and scope to use your information via Privacy Policy.
• 2.3.2We value personal information security. We strive to secure users' information to prevent information unauthorized access, disclosure, use, modification, damage, or loss.
• 2.3.3We will use a variety of security measures to ensure the security of information within reasonable security standards. For example, we will use encryption technology (for example, SSL), data anonymization and other means to protect your personal information.
• We implement trusted protection mechanisms to protect data from attacks.
• 2.3.4We have set up specialized management systems, processes and organizations to ensure the security of information. For example, we deploy access control mechanisms to ensure that only authorized personnel can access your personal data; we hold security and privacy protection training courses to raise employees' personal data protection awareness.
• 2.3.5We also ask you to understand, in the Internet industry due to the limitations of technology, rapid development and possible malicious attack, even if we do our best to strengthen security measures, it is impossible to always guarantee the one hundred percent security of information. Please be aware that the systems and communication networks you use in using our products and/or services may have security problems in other links beyond our control.
• 2.3.6In the unfortunate event of personal information being at risk, we will promptly inform you in accordance with the requirements of laws and regulations: the current situation, the possible impact of the security incident, the disposal measures we have taken or will take, and how you can prevent and mitigate the risks autonomously, and any possible suggestions, remedies for you, etc. We will promptly inform you of the relevant circumstances of the incident by mail, letter, telephone, push notification, etc. When it is difficult to inform the affected parties individually, we will issue a notice in a reasonable and effective manner. At the same time, we will also report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.
• III.How We Share, Transfer and Disclose Your Personal Information
• 3.1Sharing
• 3.1.1Sharing with consent: After obtaining your consent, we will share the information with third parties.
• 3.1.2We may share your information as required by laws and regulations, or as required by administrative or judiciary authorities pursuant to law.
• 3.1.3Anonymous, aggregate statistical data is not defined in this policy. We may store and use such information for the report of the analysis and usage patterns, etc. We reserve the right to any purpose or unilateral license third parties to use, and disclosure of anonymous summary statistics.
• 3.2Transfer
• We will not transfer your personal information to any company, organization or individual except in the following cases:
• 3.2.1Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.
• 3.2.2In the event of a merger, acquisition or bankruptcy liquidation of the service provider, or other circumstances involving mergers, acquisitions or bankruptcy liquidation, if a personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Policy, otherwise we will require the company, organization and individual to obtain your consent again.
• 3.3Public disclosure
• We will only publicly disclose your personal information in the following circumstances:
• 3.3.1After obtaining your explicit consent;
• 3.3.2Based on law: In the case that we may publicly disclose your personal information in accordance with the requirements of laws and regulations, mandatory administrative law enforcement or judicial requirements.
• IV.Your Rights
• 4.1Accessing Your Personal Information
• In addition to laws and regulations, you have the right to access and correct your personal information at any time, including:
• 4.1.1Personal Center - You can log in the personal center to view and edit your personal information;
• 4.1.2Customized records - You can log in the personal center and view, edit or delete customized records through the "Flight Customized Records" section;
• 4.2Amending or Supplementing Your Personal Information
• If you find any error in your personal information that we process, you can make a request for amendment or supplement in the way listed in "4.1 access to your personal information".
• 4.3Deleting Your Personal Information
• In the following situations, you may ask us to delete your personal information:
• If we deal with personal information in violation of laws and regulations;
• If we collect and use your personal information without your consent;
• If our handling of personal information violates the agreement between us;
• If you no longer use our products or services, or you delete the account;
• If we terminate the service and operation
• If we decide to respond to your removal request, we will also notify the entity from which we obtained your personal information and request that it be removed in a timely manner, unless otherwise required by laws and regulations, or if these entities obtain your independent authorization.
• When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but will delete it when the backup is updated.
• Information System Constraint for Automated Decision
• In some business functions, we may make decisions based solely on non-manual automatic decision mechanisms such as information systems and algorithms. If these decisions significantly affect your legal rights, you have the right to ask us for an explanation and we will provide appropriate remedies.
• 4.5In response to your requests above
• If you have any problems in the operation through the path described in article 4.1 to 4.4 or in the protection of your personal rights, you can contact us through the contact information in Article 9 of this policy.
• For security reasons, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will respond within 30 days.
• V.Protection of Minors
• We place great importance in the protection of personal information of minors. If you are a minor under the age of 18, according to the relevant laws and regulations, your parents’ or legal guardian's written consent should be obtained prior to you use of our service. If you are a legal guardian of a minor, you may contact us through the contact information specified in Article 9 where you have queries regarding the personal information of your minors.
• VI.How Your Personal Information is Transferred Globally
• In principle, the personal data we collect and generate in the People's Republic of China will be stored in the PRC.
• Please be informed that your personal data may be transferred to or accessed from overseas jurisdictions where you use our products or services with your authorization and consent.
• These jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal data is protected as it is within the People's Republic of China. For example, we may ask for your consent to the transfer of personal data, or to implement security measures such as de-identification of data before transfer.
• VII.Use of Cookies
• A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser and facilitate your experience with this site. However, you may choose to accept or reject cookies. You can prevent the application of cookies by changing your browser settings when a cookie is being sent, but as a result, you may be unable to access certain services and functions without cookies.
• VIII.Changes to the Privacy Policy
• We may change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. Whenever we make any changes to this Privacy Policy, a notice will be posted on this page.
• If changes are significant, we will show you the updated Privacy Policy in the form of notice and pop-up windows when you log in or we update the version. Please note that we will only collect, use and store your personal data according to the updated Privacy Policy after you click the "agree" button in the pop-up windows.
• IX.Contact Us
• If you have any questions about this Privacy Policy, you may contact us at the following address:
• 17th Floor, Block A, City International Plaza, No. 320 Qianshan Road, Hefei, Anhui, China   230031
• Attn: Data and Privacy Protection Center
• You can also send an email to business@VariFlight.com. We will review the issues as soon as possible and respond within 30 days after verifying your user identity.

Appendix for EU Users

• Last updated: May 24, 2019
• VariFlight is committed to protecting and respecting your privacy. We are a company established in China with registered address at Room 813, Kechuang Building, No. 860 Wangjiang West Road, High-tech District, Hefei, Anhui, and for the purpose of the General Data Protection Regulation (the “GDPR”), we are the data controller.
• Note: This Policy only applies to users who use VariFlight’s service and normally reside in the European Union. In order to use our services, you must sign the VariFlight User Service Agreement.
• This Policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of VariFlight website. Please read this Policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Policy in general or any part of it, you should not use the service.
• What types of information do we collect and how do we use it?
• Customer service information. You may provide information by contacting us via our service or email, telephone, instant chat, social media or by signing up for our newsletters or alerts. Please refer to our standard Privacy Policy for details.
• We will use your information in order to provide you with the service, in accordance with the User Agreement. As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization, we will use your information to:
•   Communicate with you;
•   Sign up for our newsletters or alerts;
•   Contact you via telephone or email;
•   Identify our users;
•   Administer and provide services and customer support per your request;
•   Enforce our terms and conditions;
•   If you have already chosen to participate in marketing (promotion), we will push you information about products, services, promotions, activities and other news that we think you are interested in.
• How do we share your personal data?
• We do not sell, rent or lease your personal information to others except as described in this Privacy Policy. We share your information with selected recipients. The categories of recipients include:
•   We will share your information with law enforcement agencies, publish authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: comply with a legal obligation, process or request;
•   Enforce our terms, conditions and other agreements, including investigation of any potential violation thereof;
•   Detect, prevent or address security, fraud or technical issues; or
•   Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction)
• We will also disclose your information to third parties:
•   If we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
•   If we or substantially all our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
• Where do we store your personal data?
• The information that we collect from you will be transferred to, and stored at/processed in China under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy.
• The security of your personal data
• Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data. We cannot guarantee the security of your information transmitted through the service or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal data against loss, theft and unauthorized use, access and modification.
• We will from time to time, provide links to the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own Privacy Policy and we do not accept any responsibility or liability for these Policies. Please check these Policies before you submit any information to these websites.
• How long do we store your personal data?
• After you have terminated your use of our service, we will store your information in an aggregated and anonymized format.
• Your rights
• Users in the European Economic Area have rights in relation to the personal data. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please email business@VariFlight.com.
• You have the following rights in relation to your personal data:
•   Access: to enquire and access personal information held by VariFlight and details about how we use it and who we share it with;
•   Portability: where we process personal information provided by you and processed by us based on contract or consent, you have the right to receive or ask us to provide your personal data (subject to any applicable law) to a third party in a structured, commonly used and machine-readable format;
•   Correction: to correct any personal data held about you that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Where you request correction, please explain in details why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below;
•   Erasure: that we erase your personal data in certain circumstance.
•   Restriction of processing to storage only: to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstance.
•   Objection: in certain circumstance, the right to restrict or object to our processing of your personal data (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered). You also have the right to object to marketing based on profiling;
•   Withdrawing consent: you can withdraw your consent at any time by emailing us at business@VariFlight.com; and
•   Complaints: if you wish to make a complaint about how we process your information, please email business@VariFlight.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your local data protection authority.
• Changes
• Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.
• Contact Us
• Questions, comments and requests regarding this policy are welcomed and should be addressed to business@VariFlight.com