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Privacy Policy
This Privacy Policy applies to all users of Aitrago Limited (“Aitrago”) and
explains how we collect, use, share, and protect your personal information. If
we decide to change our privacy policy, we will post those changes to our
website. We reserve the right to update or change our Privacy Policy at any
time. Please read this Privacy Policy carefully. By using our Products and/or
Services, you are agreeing that you are at least eighteen (18) years of age and
that you have fully understood and accepted all the terms and content of this
Privacy Policy. If you do not agree with this Privacy Policy, you may not use
our Products and/or Services.

1. How We Collect Information

Personal information is collected in the following ways:
1.1 Information you provide us directly, including information given from
account registration or by phone, information submitted in an application form
or agreement for our products and/or service, and information submitted through
the website;
1.2 Information we may receive from third parties, such as hotels and merchants
who provide hospitality, travel and related services, our distributors, any
business partners or any related entities, or a representative by your consent;
1.3 Record of your product and service purchase and usage;
1.4 When you voluntarily provide to us when visiting our official website or
participating in our online services, for example, registration in our
promotions, when you contact us on our website or via email with a question or
comment or participate in an online survey;
1.5 Other methods from which we may collect and add your Personal Information to
our customer database. If you choose to restrict our collection or use of your
personal information, it may affect the services provided to you.

2. Information We Collect

Information collected depends on the products and services you use or have used,
including, but not limited to, the following:
2.1 Required information given in account registration, including your username,
password, email, and phone number.
2.2 Payment details when purchasing Aitrago products, including your credit card
number, savings card number, and other personal information you fill in.
2.3 Information provided by you on your product, service, lifestyle or
recreational preferences, or our assumptions of your preferences based on your
purchase history.
2.4 Communication details retained during your contact with us, such as call
detail records or communication records in written form.
2.5 Information from your Aitrago account, such as payment date, ordered
service, and any other information related to your account.
2.6 If your mobile device has tracking and positioning abilities, information on
your geographical location will be collected (e.g. with GPS or Wi-Fi) when using
our service.

3. How We Use the Information We Collect

3.1 To facilitate Aitrago’s operations, such as importing your information into
our database for the purposes of analysis, research, troubleshooting, testing,
auditing, statistics and investigation.
3.2 Improvement of our products and services according to the information we
collect.
3.3 Aitrago partners in hospitality, travel and related business with other
companies to send you recommendations (or through the platform of our business
partners) of new products, special offers, or other information that may
interest you (unless you choose to opt out of receiving them).
3.4 To help you manage your products and services from Aitrago and keep you up
to date on your order status.
3.5 According to the information you provide, our customer service
representatives can provide better customer support to answer queries from you,
which could be related to products or services.
3.6 According to the information you provide, we may contact you to conduct
market research through phone call, fax, email, or mail. We can also customize
our website based on the preferences of our consumers and users.
3.7 Used for authentication, customer service, security, fraud monitoring,
archiving and backup purposes, to ensure the safety of the products and services
we offer you.
3.8 Any other purpose that is directly related to the above situations.
3.9 We will only retain your personal information for as long as needed, to the
extent permitted by law. After you contact us, we may retain your information
for as long as it is reasonably required to facilitate your use of our products
and services in the future.

4. Sharing Information

Aitrago will not sell your personal data to third parties, but will share them
in the following cases:
4.1 Sharing under explicit consent: We will share your personal data to other
parties with your knowledge.
4.2 Sharing to authorized partners: Aitrago may share your information to
third-party logistics to arrange the delivery of your product or to provide you
other services after making a purchase online. Your personal data is obtained
and processed only for specified and lawful reasons, and only required
information will be provided to our partners. We do not allow our affiliates and
partners to share or use any of your personal data for any other purpose.
4.3 Sharing to business partners whom you receive the products and services from
directly during joint business activities or promotions with Aitrago.
4.4 Sharing of information is based on law and reasonable basis, including, but
not limited to: If law, legal process, litigation and/or requests from public
and governmental authorities within or outside your country of residence
requires, we may share your personal information. In the event that we are
involved in reorganization, merger, bankruptcy or litigations, your information
may be transferred as part of that transaction. Aitrago may also disclose your
personal data under reasonable and necessary circumstances, such as to execute
our terms and conditions or to protect the customer.

5.How to visit your information

5.1 We will try to take appropriate technical measures to ensure that you can
access, update and correct your registration information or use other personal
information provided by our service.
5.2 When you visit, update, correct, and delete the aforementioned information,
we may require you to authenticate to secure your account.
5.3 You can visit the Aitrago 's website to login and help us ensure that your
information is accurate, complete and update instantly.
5.4 Whenever you voluntarily disclose your personal information, e.g. on social
media network such as Facebook, Wechat etc, such information may be collected
and used by others. Aitrago is not responsible for your personal information
disclosure. Therefore, we remind you to consider carefully whether it is
necessary to disclose your personal information.
5.5 Our business may require us to transfer your Personal Data to other
countries. We take appropriate steps to ensure that recipients of your Personal
Data are bound to duties of confidentiality and we implement measures such as
standard contractual clauses. A copy of those clauses can be obtained by
contacting our Support Center.

6. Security

6.1 We use strict procedures and security measures to protect your personal
information against unauthorized access, disclosure, use, alteration, damage, or
loss of data.
6.2 We will take all reasonable steps to protect your personal information saved
on our platform, such as from account registration, recharge and so on. These
measures include:
6.2.1 Using encryption to ensure data confidentiality;
6.2.2 Using reliable protection mechanisms to prevent your personal data from
hackers and malwares.
6.2.3 Deploying an access control mechanism to ensure that only certain
authorized employees within Aitrago can access our users’ personal data;
6.2.4 Conducting security and privacy training courses on a regular basis to
strengthen internal staff knowledge on the importance of protecting personal
data.
6.3 Aitrago makes every effort to ensure that personal data unrelated to our
operations will not be collected. We will only retain your personal data within
the time required to achieve the purpose of the Policy, unless an extension of
the retention period is needed or if it is legally permitted.
6.4 While no security procedures are completely foolproof, we make every effort
to protect your personal data.

7.Your Rights

7.1 Subject to limitations in applicable law, you are entitled to object to or
request the restriction of processing of your Personal Data, and to request
access to, rectification, erasure and portability of your own Personal Data.
7.2 Where the use of your information is based on consent, you can withdraw this
consent at any time without affecting the lawfulness of processing based on
consent before its withdrawal. Requests should be submitted by contacting us
through email.
7.3 If you are aware of changes or inaccuracies in your information, you should
inform us of such changes so that our records may be updated or corrected. You
may lodge a complaint with a supervisory authority if you consider that our
processing of your Personal Data infringes applicable law.
7.4 We retain your Personal Data as long as needed to provide services or
products to you, or as required or permitted by applicable laws, such as tax and
accounting laws.

8. Notice

8.1 We may send email or news to your devices. If you do not wish to receive
this information, you can cancel the subscription on the device according to our
instructions.
8.2 We may issue announcements to you when necessary (for example, when a
service is suspended due to system maintenance). You may not be able to cancel
these services and properties that do not belong to promotion.
8.3 We recommend that minors seek parental or guardian consent and guidance
before submitting personal information.

9.Legal basis for data processing

We process Personal Data for the purposes set out in this Privacy Policy, as
described above.
9.1 Our legal basis to process personal data includes processing:
9.1.1 Necessary for the performance of the contract with you. For example, to
provide you with the services you request and to identify and authenticate you
so you may use the Sites;
9.1.2 Necessary to comply with legal requirements. For example, to comply with
applicable accounting rules and to make mandatory disclosures to law enforcement
9.1.3 Necessary for our legitimate interests. For example, to manage our
relationship with you, to ensure the security of our services, to communicate
with you about our products and services.
9.2 In some instances, you may be required to provide us with Personal Data for
processing as described above, in order to provide you all of our services, and
for you to use all the features of our Sites.

10. Final Note

Except the certain services, all of our services apply to this privacy policy.
We have the right to revise and update this privacy policy at any time. If we
make significant changes to our privacy policy, we will release the latest one
on our website.