Privacy Policy
Last updated: Aug/21/2024
This Privacy Policy(the "Policy") is applicable to the Website da.flylinking.com that is provided by Tuotuo Digital Technology (Beijing) Co., Ltd., with registered address inRoom 1-901-1, 9th Floor, No. 28 Chengfu Road, Haidian District, Beijing, China(hereinafter referred to as "We", or "Us", "ours") .
This Policy is part of the Terms and Conditions of da.flylinking.com (Terms of Usage). For matters not covered in this policy, the Terms and Conditions of da.flylinking.com shall prevail.
We understand the importance of Your Personal Data and are dedicated to protecting it. We are committed to maintaining Your trust and adhere to the following principles to safeguard Your Personal Data: Consistent Rights and Responsibilities, Clear Purpose, Choice and Consent, Minimum Sufficiency, Ensuring Security, Subject Participation, Transparency.
Additionally, We promise to implement appropriate security measures to protect Your Personal Data in accordance with industry-standard security practices. This Policy will help You understand the following matters:
1. how do We collect and Use Your Personal Data
2. how do We Use Cookies and similar technologies
3. how do We process Personal Data
4. how do We share, transfer and disclose Your Personal Data
5. how do We protect Your Personal Data
6. how can You manage Your Personal Data
7. how do We deal with the Personal Data of minors
8. how do We transfer Your Personal Data around the world
9. how do We update the policy
10. how to contact Us
Please read and understand this policy carefully before using the Website. By using the Website, You acknowledge that You have read, understood, and agreed to this policy.
Definitions
The following capitalized terms shall bear the meaning ascribed thereto. Definitions of capitalized terms that are not defined in this Policy can be found in other parts of the respective Agreement.
“Agreement” means terms and conditions, the Terms of Usage, that are made and entered into between You and Us.
“Controller” means the entity which determines the purposes and means of the processing of Personal Data, and for the purpose of this Policy it means Us.
“Data Protection Laws” means (i) The Personal Data (Privacy) Ordinance (the “PDPO”) in Hong Kong SAR; (ii) other legislation and regulatory requirement in force from time to time which apply to You and Us respectively relating to Use of Personal Data/Information; and (iii) the guidance and codes of practice issued by the relevant data protection or Supervisory Authority and applicable to either Party, in each cases as may be amended, supplemented, or replaced from time to time.
“Personal Data” means any information relating to an identified or identifiable natural person when using FlyLink Service; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, which, in the context of this Policy and Agreement, means: (1) Personal Data that is transferred from Buyer to Merchant; (2) Personal Data that You shared to by the FlyLink URL or QR code; (3) Personal Data of You and Buyer; and (3) Personal Data that is transferred from Buyer, Merchant, You to Processor as part of the Transaction Data.
“Processor” means Us, Camel Supply Chain Management (Asia) Limited (“Camel”), or any affiliates of third party that processes Personal Data on behalf of Camel.
“Supervisory Authority” means the relevant supervisory authority with jurisdiction over the Data Protection Laws.
“Transaction Data” means any information related to a card or a payment instrument for effectuating the Transaction among Buyer, Merchant and You. This may include card number assigned the card by the issuing back, Card Holder/Buyer/Payer name, expiration date or the card, CVV code, the name and location of the Card Holder/Buyer/Payer where the Transaction occurred. Transaction Data may include Personal Data.
Definitions not defined in this Policy shall apply to the Agreement.
1. How do We collect and Use Your Personal Data
We will only collect and Use Your Personal Data for the following purposes described in this Policy:
To provide You with relevant services of the Website.If You choose to Use certain functions, You will need to provide the necessary information for those functions. This may include, but is not limited to, Your identity information, contact details, address, company information, and relevant license documents.You authorize Us to obtain Your account information from the third-party platform You Used to register on the Website. Additionally, We may inquire and verify Your relevant information from qualified third-party sources to determine whether to provide You with specific functions. By Using the Website, You agree to authorize Us to Use this information.
We may collect information about You when You visit our Website or Use our FlyLink Service, including the following:
Registration and Use information – when You register to Use our Service by establishing an FlyLink Account, We will collect Personal Data as necessary to offer and fulfill the Service You request. Depending on the Service You choose, We may require You to provide Us with Your name, postal address, telephone number, social media account, email address and identification information to establish an FlyLink Account or track Your FlyLink URL or QR code.
Transaction and experience information – when You Use our Service or access our Website, for example, to make commissions from Merchant, to receive money, to process FlyLink payments, We collect information about the Transaction, as Well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, Merchant information, Buyer information, including information about any funding instruments Used to complete the Transaction.
Information about Your public profile and Your friends and contacts – it may be easier for Us to help You transact with Your friends and contacts when Using FlyLink Service if You choose to connect Your contact list information with Your FlyLink Account or if Your FlyLink Account profile is publicly available. If You establish an account connection between Your device or a social media platform and Your FlyLink Account or FlyLink URL or QR code, We will Use Your contact list information (such as name, address, email address) to improve Your experience when You Use our Service.
To ensure the Website works Well and identify any abnormal issues, We will collect information about the functions You Use and how You Use them. This information includes:
Device information: We will receive and record the relevant information of Your device (such as device model, operating system version, device settings, unique device identifier and other software and hardware feature information) information about the location of the device (such as IP address, GPS location and sensor information such as Wi-Fi access point, Bluetooth and base station that can provide relevant information).
Log information: when You Use the Website, the system will automatically collect Your detailed Usage of our services and save them as relevant network logs. For example, Your search query content, IP address, browser type, telecom operator, language Used, access date and time, and the Web page records You visited.
Transaction Information: We collect information related to the transactions made through the payment links, including the amount, date, and the products purchased.
Communication information: when You contact Us, We may save Your communication/call records and contents as Well as Your contact information, so as to contact You or help You solve problems, or record the solutions and results of related problems.
To comply with applicable Data Protection Laws and regulations and regulatory requirements and/or any other regulations, orders required by Supervisory Authority, provide services to You and improve service quality, or ensure the safety of Your FlyLink Account, We will Use Your information in the following situations:
To achieve the purpose of "how do We collect Personal Data" in this Policy;
To let You know the status of the Website’s services, We will send You service reminders;
To ensure the stability and security of services, We will Use Your information for identity verification, security prevention, fraud monitoring, prevention or prohibition of illegal activities, risk reduction, archiving and backup purposes;
To report to relevant authority according to applicable laws and regulations or regulatory requirements;
To invite You to participate in customer research related to the Website; We will conduct comprehensive statistics, analysis and processing of Your information, so as to provide You with more accurate, personalized, fluent and convenient services, or help Us evaluate, improve or design products, services and operational activities. We may provide You with marketing activity notices, commercial electronic information or advertisements You may be interested in according to the above information. If You do not want to receive such information, You can choose to unsubscribe according to the method We prompted.
Other Uses. When We want to Use the information for other purposes not specified in this policy, We will ask for Your consent in advance.
Exceptions with authorization. According to relevant applicable Data Protection laws and regulations, it is not necessary to obtain Your authorization and consent to collect Your Personal Data in the following situations:
Related to national security and national defense security;
Related to public security, public health and major public interests;
Related to criminal investigation, prosecution, trial and execution of sentences;
For the purpose of safeguarding the life, property and other major legitimate rights and interests of the Personal Data subject or other individuals, but it is difficult to get Your own consent;
The Personal Data collected is disclosed to the public by Yourself;
Collecting Personal Data from legally disclosed information, such as legal news reports, government information disclosure and other channels;
Necessary for signing the contract according to Your requirements;
It is necessary for maintaining the safe and stable operation of the Website provided, such as discovering and disposing the faults of products or services;
Necessary for legal news reports;
When it is necessary for an academic research institution to carry out statistical or academic research based on the public interest, and provide academic research results to the public, provided that it de-identifies the Personal Data contained in the results;
Other circumstances prescribed by laws and regulations.
If We stop operating the Website or terminate FlyLink Service for You, We will stop collecting Your Personal Data in a timely manner, and We will notify You individually or through an announcement if We decide to stop operations or termination. Additionally, We will delete or anonymize the Personal Data We hold.
2. How do We use Cookie and similar technologies
Cookie. To ensure the normal operation of our services, We will store a small data file named Cookie on Your computer or mobile device. A Cookie Usually contains an identifier, a site name, and some numbers and characters. With the help of Cookie, We can store Your operation or preference data. We will not Use Cookie for any purpose other than the purpose stated in this Policy. You can manage or delete Cookie according to Your preference. For how to set up a Cookie, You can refer to the relevant tips of Your browser. You can clear all Cookie saved on Your computer or mobile device. But if You do this, You need to change the User settings in person every time You Use our services.
Site beacons and pixel tags. In addition to Cookie, We will also Use other similar technologies such as site beacons and pixel tags on the Website. For example, the email We send You may contain a click URL that links to the Website content. If You click the link, We will track this click to help Us understand Your product or service preferences and improve customer service. A site beacon is Usually a transparent image embedded in a Website or e-mail. With the help of the pixel label in the email, We can know whether the email is opened. If You don't want Your activities to be tracked in this way, You can unsubscribe from our mailing list at any time.
Do Not Track. Many Web browsers are equipped with the Do Not Track function, which can issue Do Not Track requests to the Website. At present, the main Internet standards organizations have not set up relevant policies to regulate how Websites should respond to such requests. But if Your browser has enabled Do Not Track, then the Website will respect Your choice.
3. How do We process Personal Data
We may process Your information for the following reasons:
To operate the Website and provide the Service, including to:
Inititate a payment, send or request money, settlement, make a commission;
Authenticate Your access to FlyLink Account;
Communicate with You about Your FlyLink Account, the Website, the Service;
Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes; and
Keep Your FlyLink Account and financial information up to date.
To manage our business needs, such as monitoring, analyzing, and improving the FlyLink Service and the Website’s performance and functionality.
To manage risk and protect the Website, the Service and You from fraud by verifying Your identity.
To make to You about our products and services and the products and services of unaffiliated businesses. We may also process Your Personal Data to uniquely tailor the marketing content and certain Service or Website experiences to better match Your interests.
To provide You with location-specific options, functionally or offers if You elect to share Your geolocation information through the Service. We will Use this information to enhance the security of the Website and Service and provide You with location-based Service, such as advertising, search results and other personalized content.
To comply with our obligations and to enforce the terms of our Service, including to comply with all applicable laws and regulations.
4. How do We share, transfer and disclose Your Personal Data
Sharing:
We will not share Your Personal Data with any company, organization or individual, except for the following circumstances:
Share with explicit consent: after obtaining Your explicit consent, We will share Your Personal Data with other parties.
We may share Your Personal Data with others in accordance with laws and regulations, or according to the mandatory requirements of the competent government departments or judicial authority.
Deal with Your disputes or disputes with others as You need.
In line with the relevant agreements signed with You (including the electronic agreements signed online and the corresponding Flyway platform rules) or other legal documents.
Based on the social and public interests in line with laws and regulations.
Sharing with our Affiliates:
Your Personal Data may be shared with our affiliates. We will only share necessary Personal Data and are bound by the purposes stated in this Policy. If the affiliates want to change the purpose of processing Personal Data, it will ask for Your authorization again. For the FlyLink Service, our affiliate includes but not limited to:
Sharing with service providers:
Only for the purpose stated in this Policy, some of our services will be provided by service providers. We may share some of Your Personal Data with partners to provide better customer service and User experience. We will only share Your Personal Data for legitimate, proper, necessary, specific and clear purposes, and only share the Personal Data necessary for providing services. Service providers have no right to Use the shared Personal Data for any other purposes. Currently, our service providers include but are not limited to the following types:
Third party payment company
Third party data or technical service company
Logistics service provider
Customs declaration agency
E-commerce platform
Cooperative financial institutions, including but not limited to banks, factoring companies, financing guarantee companies, re-factoring companies, small loan companies, foreign exchange service providers, Card Schemes or other qualified entities that can provide You with financial services.
Transfer:
We will not transfer Your Personal Data to any company, organization or individual, except for the following circumstances:
Transfer with explicit consent: after obtaining Your explicit consent, We will transfer Your Personal Data to other parties;
Comply with the relevant agreements signed with You (including the electronic agreements signed online and the corresponding platform rules) or other legal documents;
In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of Personal Data, We will require the new companies and organizations holding Your Personal Data to continue to adhere to this Policy. If they cannot comply, We will ask them to obtain Your authorization again.
Disclosure.
We will only publicly disclose Your Personal Data in the following circumstances:
After obtaining Your explicit consent;
Disclosure based on Law: under the mandatory requirements of laws, legal procedures, lawsuits or supervisory authorities, We may disclose Your Personal Data.
5. How do We protect Your Personal Data
We have Used security protection measures that meet the industry standards to protect the Personal Data You provide, to prevent unauthorized access, public disclosure, Use, modification, as Well as damage or loss of data. We will take all reasonable and feasible measures to protect Your Personal Data. For example, We will Use encryption technology to ensure the confidentiality of data; We will Use trusted protection mechanism to prevent data from malicious attacks; We will deploy access control mechanisms to ensure that only authorized personnel can access Personal Data; And We will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting Personal Data.
We have an advanced data security management system centered around data and its life cycle. This system enhances security across multiple dimensions, including organizational structure, system design, personnel management, and product technology.
We will take all reasonable and feasible measures to ensure that irrelevant Personal Data is not collected. We will only retain Your Personal Data for the period required to achieve the purpose stated in the Policy, unless it is necessary to extend the retention period or permitted by law.
The Internet is not an absolutely safe environment, and e-mail and instant messaging are not encrypted. We strongly recommend that You do not send Personal Data in this way. Please Use a complex password to help Us ensure the security of Your account.
The Internet environment is not one hundred percent safe. We will try our best to ensure or guarantee the security of any information You send to Us. When Using the Website for online transactions, You inevitably have to disclose Your Personal Data, such as contact information or contact address, to the trading partner or potential trading partner. Please protect Your Personal Data properly and provide it to others only when necessary. If You find that Your Personal Data, especially Your account or password, is leaked, please contact our customer service immediately, so that We can take corresponding measures according to Your application. Please note that the information You voluntarily share or even publicly share when Using our FlyLink service may involve Your or others' Personal Data or even personal sensitive information. Please consider more carefully whether to share or even publicly share relevant information when Using our services.
After the unfortunate Personal Data security incident, We will inform You in a timely manner in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures We have taken or will take, the suggestions You can independently prevent and reduce risks, and the remedial measures for You. We will timely inform You of the relevant information of the event by email, letter, telephone, pUsh notice and other ways. When it is difficult to inform the Personal Data subject one by one, We will take a reasonable and effective way to issue an announcement. Additionally, We will actively report and respond to Personal Data security incidents as required by regulatory authorities.
6. How can You manage Your Personal Data
In accordance with applicable laws, regulations, and standards, as Well as prevailing practices in major countries and regions, We guarantee that You can exercise the following rights over Your Personal Data:
Access Your Personal Data. You have the right to access Your Personal Data. If You want to exercise Your data access right, You can also access it by Yourself in the following ways:
Account information - If You want to access or edit Your account's Personal Data, payment information, recipient info, order details, change Your password, or add security information, You can do so by visiting the personal center in the Flyway Platform.
Order information - You can check or clear Your order records and transaction records in the personal center in the Flyway Platform.
If You are unable to access these Personal Data in the above way, You can send an email to service@flylinking.com, We will reply to Your request within 10 business days and resolve the problem as soon as practicable.
For other Personal Data generated while Using the FlyLink Service, We will provide it to You as long as it doesn't incur excessive costs.
Correct Your Personal Data. When You find that there is any error in Your Personal Data processed by Us, You have the right to ask Us to make a correction. You can perform such operations by visiting the personal center. If You are unable to correct such error through the above method, You can send an email to our email address, We will reply to Your correction request within 10 business days.
Delete Your Personal Data. Generally, the information will be retained for no more than 6 years after the end of the business relationship, unless otherwise required by applicable laws and regulations of the jurisdiction where We provides Service. In the following situations, if You want Us to delete Your Personal Data, please contact Us by sending an email to our email address:
If We deal with Personal Data in violation of laws and regulations;
If We collect and Use Your Personal Data without Your consent;
If our behavior of processing Personal Data violates the agreement with You;
If You no longer Use the Website, or You cancel Your account;
If We no longer provide You with products or services.
If We decide to respond to Your deletion request, We will also notify the entities that obtain Your Personal Data from Us at the same time, requiring them to delete in a timely manner, unless otherwise specified by laws and regulations, or these entities are authorized by You independently.
When You delete information from our Service, We may not immediately delete the corresponding information in the backup system, but We will delete the information when the backup is updated.
Change the scope of Your authorization. Certain function might need some basic Personal Data to complete (see the "first part" of this Policy). For the collection and Use of additional collected Personal Data, You can give or withdraw Your authorized consent at any time. You can do it by sending an email to our email address. When You withdraw Your consent, We will no longer process the corresponding Personal Data. However, Your decision to withdraw Your consent will not affect the previous Personal Data processing based on Your authorization. If You do not want to accept the commercial advertisement We sent You, You can cancel it at any time by sending an email to our email address.
Cancel the account. You can cancel the previously registered account at any time. You can do it by sending an email to Us. After the cancellation of the account, We will stop providing products or services for You, and delete Your Personal Data according to Your requirements, unless otherwise specified by laws and regulations.
Obtain the copy of Personal Data. You have the right to get a copy of Your Personal Data. You can do it by Yourself by sending an email to Us. If technically feasible, such as when data interfaces are compatible, We can also directly transfer a copy of Your Personal Data to a third party designated by You, based on Your request.
Constrain automatic decision of information system. In some functions, We may make decisions based solely on automated mechanisms, such as information systems and algorithms. If these decisions significantly affect Your legitimate rights and interests, You have the right to ask Us for an explanation, and We will provide reasonable adjustments.
Response to Your above request. To ensure safety, You may need to provide a written request or prove Your identity in other ways. We may ask You to verify Your identity before processing Your request. We will respond within 10 business days. If You are not satisfied, You can also file a complaint with the relevant regulatory authorities. For reasonable requests, We generally do not charge a fee. However, for repeated requests that exceed a reasonable limit, We may charge a fee based on the situation. For requests that are unfounded, require extensive technical efforts (such as developing a new system or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (such as involving information stored on backup tapes), We may refuse them. In the following cases, according to the requirements of laws and regulations, We will not be able to respond to Your request:
Those directly related to national security and national defense security to the applicable jurisdiction;
Directly related to public security, public health and major public interests;
It is directly related to criminal investigation, prosecution, trial and sentence execution;
There is sufficient evidence that You have subjective malice or abuse of rights;
Responding to Your request will cause serious damage to the legitimate rights and interests of You or other individuals and organizations.
Involving commercial secrets of other person.
7. how do We deal with the Personal Data of minors
Without the consent of parents or guardians, minors are not allowed to create their own User accounts. If You are a minor, please ask Your parents or guardian to read this Policy carefully, and Use our services or provide information to Us with the consent of Your parents or guardian.
For the case of collecting minors' Personal Data by Using the Website with the consent of parents or guardians, We will only Use, share, transfer or disclose this information when it is permitted by laws and regulations, or it is expressly agreed by parents or guardians, or it is necessary to protect minors.
8. how do We transfer Your Personal Data around the world
Our services are global, and information may be stored and processed in different country / region within our business scope and in the region where We cooperate with service providers. The information collected by Us may be transferred to destinations outside jurisdictions of Your residence or where We locate. These jurisdictions may have different information protection rules from Your country, including the transmission of information to regulatory authorities or to employees operating abroad who process information on behalf of Us or our suppliers and being engaged in the business of fulfilling Your requirements and providing support services. However, We will take measures to ensure that any such transmissions comply with applicable Data Protection Laws and ensure that Your information protection complies with the standards described in this Policy. By agreeing to this Policy, or submitting Your information, You agree to transfer, store or process. We will take all reasonable and necessary steps to ensure that the information is processed safely and in accordance with this Policy and relevant information protection regulations.
9. how do We update the policy
This Policy is subject to change. Without Your explicit consent, We will not reduce Your rights under this Policy. We will post any changes to this Policy on this page. For major changes, We will also provide more significant notices (including for some services, We will send a notice by email to explain the specific changes in privacy policy). The major changes in this policy include but are not limited to:
Significant changes have taken place in our service model. Such as the purpose of processing Personal Data, the type of Personal Data processed, the way of Using Personal Data, etc;
We have had major changes in terms of control and so on. Such as the change of information Controller caused by merger and reorganization, etc;
The main objects of Personal Data sharing, transfer or public disclosure have changed;
Significant changes have taken place in Your right to participate in the processing of Personal Data and the way You exercise it;
When our responsible department for dealing with Personal Data security, contact information and complaint channels change;
When the Personal Data security impact assessment report indicates that there is a high risk.
We will also archive the old version of this Policy for Your reference. However, We strongly recommend that You keep a copy of this policy for Your records.
10. how to contact Us
If You have any questions, comments or suggestions about this privacy policy, please contact Us by email to Us. Generally, We will reply within 10 business days.
If You are not satisfied with our reply, especially if our Personal Data processing behavior damages Your legitimate rights and interests, You can also complain or report to the regulatory authorities.
In this Policy We have indicated the categories and types of Personal Data collected about You, the purpose for collecting this information, and Your rights relating to our collection of information. We do not sell any Personal Data.
For any request You may have in connection with the aforesaid, You may contact Us at service@flylinking.com. We may need to verify Your identity before responding to Your request.