Privacy Policy

 

March 25th, 2026

 

Welcome to the products and services of Fliggy AI Open Platform (the “Platform”) provided by Zhejiang Fliggy Network Technologies Co., Ltd. and its affiliates (“we” or “us”).

 

In the course of your registration and use of the Platform, we may process your personal information. We understand the significance of this responsibility and therefore have formulated this Personal Information Protection Policy (the “Policy”) to explain how we collect, use, provide, store, delete, and protect your personal information, and how you may manage your personal information.

 

Before you start registering and using the Platform, please read and understand this Policy carefully, especially those provisions highlighted in bold/bold underline, to ensure that you fully understand and agree before you begin using the Platform. If you have any questions about this Policy, you may contact us through the contact methods at the end of this Policy, and we will do our best to answer them.

 

I. Collection and Use

  (1) Account Registration and Real-Name Verification

You may submit your mobile phone number and verification code to register a Platform account. Before you actually request to invoke the product and technical capabilities provided by the Platform, you must submit your identity document type and number to complete real-name verification. If you only browse the Platform, you do not need to register an account.

 

  (2) Browsing, Search, and Usage Records

During your use of the Platform, we may automatically record your browsing, search, and invocation of product and technical capabilities, as well as your device information (MAC address, device brand and model) and IP address.

 

We will record the input content you provide and the output content generated when you invoke product and technical capabilities. We strongly recommend that you do not provide us with data or information that can identify a specific individual. If you use these product and technical capabilities to provide services to your users, you must provide them with written notice of the foregoing.

 

  (3) Customer Support Records

When you contact our support team through a DingTalk group or other communication methods, we may collect the content of your communications with our staff in order to provide you with services.

 

II. Provision

  (1) Sharing

Unless we obtain your consent or have another lawful basis under applicable laws, we will not share your personal information with any other third party.

 

  (2) Entrusted Processing

We may entrust a third party to process your personal information in accordance with the purposes and methods instructed by us so that such third party may provide certain services or perform certain functions for us on our behalf, including affiliated parties that provide us with technical infrastructure services. We will only entrust processing for the lawful, legitimate, necessary, specific, and clear purposes set out in this Policy. Such third party may only access the information necessary to perform its duties, and we will also require that it not use such information for any other purpose beyond the scope of entrustment. If an authorized partner uses your information for purposes not entrusted by us, it shall obtain your separate consent.

 

  (3) Transfer

If we need to transfer personal information due to merger, division, dissolution, or being declared bankrupt, we will inform you of the recipient’s name (or full name) and contact information. The recipient will continue to perform this Policy and other statutory obligations. If the recipient changes the original purpose or method of processing, it shall obtain your consent again.

 

  (4) Public Disclosure

We will only publicly disclose your personal information under the following circumstances: where, based on your active choice or other separate consent, we may publicly disclose your personal information; where we determine that you have violated applicable laws or the Platform rules, or where necessary to protect the legitimate rights and interests of other users and the general public, we may disclose information about you, including the relevant violations and the measures we have taken against you.

 

  (5) Cessation of Operations

If we cease operating the Platform, we will promptly stop collecting your personal information and delete or anonymize your personal information in accordance with this Policy.

 

  (6) Circumstances Where Consent Is Not Required by Law

You understand that, under applicable laws, in the following circumstances, a third party’s receipt and use of your personal information, or our transfer or public disclosure of your personal information, does not require your authorization and consent: where necessary for entering into or performing a contract at your request; where necessary for performing statutory duties or obligations; where necessary to respond to public health emergencies, or in emergencies to protect the life, health, and property safety of natural persons; where personal information is processed within a reasonable scope for news reporting, public opinion supervision, and other acts carried out in the public interest; and other circumstances as provided by applicable laws.

 

III. Storage

  (1) Retention Period

We will retain your personal information only for the period necessary to achieve the purposes described in this Policy, unless laws require mandatory retention. We mainly determine the retention period based on the following criteria: completing the processing purposes related to you and maintaining relevant business records to respond to your potential inquiries or complaints; ensuring the security and quality of the services we provide to you; whether you consent to a longer retention period; needs related to the statute of limitations; and whether there are other special agreements or legal and regulatory requirements regarding retention periods. After the retention period expires, we will delete or anonymize your personal information in accordance with applicable laws.

 

  (2) Storage Location

In principle, personal information collected and generated within China will be stored within China in accordance with applicable law. Unless all prerequisites required by applicable law are satisfied (e.g., necessary assessments/filings, obtaining your separate consent, etc.), we will not transmit such personal information outside of China or allow others to access such personal information from outside of China.

 

  (3) Storage Security

We have adopted industry-standard, reasonable, and practicable security measures to protect your information against unauthorized access, public disclosure, use, modification, damage, or loss, including encryption, access controls, and necessary security protection mechanisms.

 

We have established and implemented a cybersecurity and data security management system, appointed a person in charge of personal information protection, and set up a dedicated organization. Through training courses and examinations, we continuously enhance employees’ awareness of the importance of protecting personal information.

 

If a personal information security incident occurs, we will promptly initiate an emergency response plan and take reasonable and necessary measures to minimize the impact on you. We will, in accordance with applicable laws, inform you of the basic situation and possible impact of the security incident and report the handling of the incident to the competent regulatory authorities.

 

IV. Deletion

You may request that we delete your personal information under the following circumstances: where our processing of personal information violates laws and regulations; where we collect or use your personal information without obtaining your explicit consent; where our processing seriously violates our agreement with you; where the processing purpose has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose; or where we stop providing products or services, or the retention period has expired.

 

Due to limitations of applicable laws and security technologies, we may not be able to immediately delete your personal information from backup systems. We will securely store your personal information and restrict any irrelevant processing until the backups can be deleted or anonymized.

 

V. Your Rights

We safeguard your right to know and right to decide regarding personal information. You may exercise your rights to access, correct, supplement, delete, withdraw consent, and cancel your account through relevant pages of the Platform. If such pages do not yet provide operable functions, you may contact us through the contact methods at the end of this Policy, and we will respond to your request within 15 days.

 

VI. Protection of Minors

We attach great importance to the protection of minors. As stated in the User Service Agreement, we currently only open registration to individual developers who are 18 years of age or older. If we discover that you are a minor under the age of 18, we will suspend providing Platform services to you and delete your personal information, unless otherwise required by applicable law.

 

VII. Updates

Due to product iterations or other reasonable reasons, we may update this Policy and notify you through methods such as publication on the Platform pages. If you do not agree to the updated Policy, you are advised to stop using the Platform. If you continue to use the Platform, we will deem that you have agreed to the updated Policy.

 

VIII. Contact

We have appointed a person in charge of personal information protection and set up a dedicated organization. You may contact the person in charge of personal information protection at fliggyPIP@service.alibaba.com. We will not respond to questions unrelated to personal information protection.