Introduction

Jinko (referred to as "we", "us", or "our") is a travel assistant app committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you use our services (the "Services"), which include our application, website, and any related offerings. By using Jinko, you agree to the practices described in this Privacy Policy.

Information Collected

We may collect various types of information from and about you when you use our Services, including:

• Personal Information: Information that identifies you, such as your name, email address, phone number, and account credentials (if you create an account or join our waitlist).

• Travel and Booking Information: Details you provide when searching for or booking travel, such as travel destinations, booking preferences, traveler names, passport or visa information (if required for bookings), and any itinerary details.

• Payment Information: If you make a purchase or booking through our Services, we (or our payment processor) may collect billing details, such as credit card numbers and billing addresses. (Note: We do not store full payment card details on our own servers; transactions are handled through secure third-party payment processors.)

• Device and Usage Data: Technical information automatically collected when you interact with our Services. This may include your IP address, browser type, device type, operating system, unique device identifiers, and information about how you interact with our app or website (e.g., pages viewed, features used, dates and times of visits, and other usage statistics).

• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to enhance your experience, analyze usage of our Services, and for security and analytics. These technologies may collect data about your browsing behavior on our website or app. You can control cookies through your browser settings and other tools.

• Communications: If you contact us directly (for example, through customer support or feedback forms) or interact with our AI travel assistant, we may receive the content of your messages and any additional information you choose to provide.

  How Information is Used

We use your information for various purposes in operating and improving our Services, including:

• Providing and Personalizing Services: To operate the Jinko travel assistant and provide you with the travel information, recommendations, and booking services you request. This includes using your data to personalize content (such as tailoring travel recommendations to your preferences).

• Processing Transactions and Bookings: To facilitate travel bookings or purchases you make, including processing payments, confirming reservations, sending tickets or booking confirmations, and communicating with you about your travel arrangements.

• Communication: To send you important notices and updates, such as booking confirmations, itinerary changes, alerts about your trips, administrative messages, and customer service responses. We may also respond to your inquiries or support requests.

• Marketing (with Consent): To send you newsletters, promotions, or offers about travel deals, new features, or other products and services that may interest you. We will only do this if you have given us consent, and you can opt out of marketing communications at any time.

• Improvement and Analytics: To understand how users interact with our Services and to improve our offerings. For example, we may analyze usage data to troubleshoot issues, develop new features, and enhance user experience.

• Security and Fraud Prevention: To maintain the safety and integrity of our Services. Your information may be used to monitor for fraudulent activities, secure user accounts, and detect and prevent malicious or unauthorized activities.

• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests. For instance, we may use and disclose data as required to meet national security or law enforcement requirements, tax and accounting obligations, or other legal responsibilities

  Legal Basis

If you are located in certain jurisdictions (such as the European Economic Area or the United Kingdom), we rely on the following legal bases to process your personal data:

• Consent: We process certain information based on your consent. For example, when you subscribe to a newsletter or opt in to receive marketing, you have given consent for us to use your data for that specific purpose. You have the right to withdraw your consent at any time.

• Contractual Necessity: When we need to process your data to provide you with Services that you have requested or to fulfill our contract with you. For example, when you book a hotel or flight through Jinko, processing your personal information (like your name and payment details) is necessary to complete the transaction.

• Legal Obligation: We process personal data to comply with our legal obligations. For instance, we may retain transaction records to fulfill tax and accounting requirements or disclose information if required by court order.

• Legitimate Interests: We process data as needed for our legitimate business interests, provided those interests are not outweighed by your data protection rights. For example, using cookies to improve website performance, or using your email to send service updates (unless you have opted out), may fall under our legitimate interests. When we rely on legitimate interests, we consider and balance any potential impact on your rights.

  Sharing

We do not sell your personal information to third parties. However, we may share your information with third parties in certain circumstances, as outlined below:

• Service Providers: We share information with trusted third-party companies that perform services on our behalf. These include cloud hosting providers, analytics services, payment processors, customer support tools, and other IT service providers. These parties are contractually obligated to keep your information confidential and to use it only for the purposes of providing their services to us.

• Travel Partners and Booking Providers: When you book travel services (such as a hotel, flight, or car rental) through Jinko, we will share the necessary personal information with the relevant travel providers (for example, airlines, hotels, or booking agencies) to fulfill your reservation. This may include your name, contact details, and travel details needed to complete the booking.

• Affiliates and Business Transfers: We may share information with our parent company, subsidiaries, joint ventures, or other companies under common control (if any), in which case we will require those recipients to honor this Privacy Policy. If Jinko is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, your information may be transferred as part of that transaction. In such cases, we will notify you (for example, via email or a notice on our site) of any change in ownership or use of your personal data.

• Legal and Compliance: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a law enforcement agency or regulatory body). We may also share information in good faith if we believe it is necessary to: (a) protect our rights, privacy, safety, or property, or that of the public; (b) detect, prevent, or address fraud, security, or technical issues; and (c) enforce our Terms of Service or other agreements.

• With Your Consent: Apart from the cases listed above, we will ask for your consent before sharing your personal information with third parties, if your consent is required in a specific situation.

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. For example, we may retain certain transaction details for accounting or legal compliance purposes. When we no longer have an ongoing legitimate business need to process your personal data, we will either delete it or anonymize it (so that it can no longer be associated with you). If deletion or anonymization is not immediately possible (for example, because the data is stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible. If you request deletion of your data, we will take reasonable steps to erase your personal information, unless we are required to retain it due to legal obligations or other legitimate reasons (in which case, we will inform you of those reasons).

Transfers

Jinko operates globally, and as a result, your personal information may be transferred to and processed in countries other than your own. This could include jurisdictions that are not subject to the same data protection laws as your home country. For instance, if you are located in the European Union, your data may be transferred to the United States or other countries where our servers or service providers are located. In all such cases, we take steps to ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws. These safeguards may include measures such as standard contractual clauses approved by the European Commission, or verifying that the recipient country has been deemed to have an adequate level of data protection by relevant authorities. By using our Services, you acknowledge that your information may be transferred to facilities located outside of your country of residence.

User Rights

You have certain rights regarding your personal data. These rights may vary depending on your location and the applicable data protection laws, but we strive to honor the requests of all users to the extent possible. Your key rights include:

• Right to Access: You can request confirmation of whether we are processing your personal data and, if so, request a copy of the information we hold about you.

• Right to Rectification: If any of your personal information is inaccurate or incomplete, you have the right to request correction or updating of that data.

• Right to Erasure: You can request that we delete your personal data if it is no longer necessary for the purposes for which we collected it, or if you have withdrawn consent (where applicable) or object to our processing (and no other legal basis overrides your objection). We will honor deletion requests provided we do not have a legal obligation to retain the data.

• Right to Restrict Processing: You have the right to ask us to limit the processing of your personal data in certain circumstances, such as while we address a complaint about data accuracy or if you have objected to our processing.

• Right to Object: You may object to our processing of your personal information when such processing is based on legitimate interests or involves direct marketing. If you object, we will consider whether our grounds for processing override your rights and freedoms. If it’s direct marketing that you object to, we will stop processing your personal information for that purpose.

• Right to Data Portability: For data you have provided to us and which we process by automated means on the basis of consent or contract, you have the right to request a copy in a structured, commonly used, and machine-readable format. You also have the right to request that we transmit this data to another service provider, where technically feasible.

• Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.

• Right to Lodge a Complaint: If you believe that we have infringed your privacy rights, you have the right to lodge a complaint with a supervisory data protection authority in your jurisdiction (for example, a Data Protection Authority in the EU or a state regulator in the U.S.). We would, however, appreciate the chance to address your concerns before you do so, and welcome you to contact us directly with any complaint.

We will not discriminate against you for exercising any of these rights. To exercise your rights, please contact us using the information provided in the Contact Information section below. We may need to verify your identity before fulfilling certain requests, to ensure that your personal data is not disclosed to someone who does not have the right to receive it.

Data Security

We take the security of your personal information seriously. We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of sensitive information (both in transit and at rest, where applicable), regular security assessments, and restricting access to personal data to employees and contractors on a need-to-know basis. Despite our efforts, please note that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. You should also take care with how you handle and disclose your personal information and avoid sending sensitive information through insecure channels.

Changes to the Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will revise the "Effective Date" at the top of this policy. If the changes are significant, we may also provide a more prominent notice (such as by email notification or a notice on our website or within the app). We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the personal information we collect. Your continued use of the Services after any changes to this Privacy Policy have been posted will signify your acceptance of those changes.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

• Email: privacy@gojinko.com