### FLYINSONO Privacy Policy

##### Last Updated: 2023-03-16.

Thank you for using FLYINSONO! We are committed to maintaining your trust in us, and abide by the principle of consistency of power and responsibility, the principle of clear purpose, the principle of choice and consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject participation and the principle of openness and transparency to protect your personal information. At the same time, we have formulated this privacy policy in accordance with the Internet Security Law of the People's Republic of China, the Personal Information Security Specification of Information Security Technology and other relevant laws and regulations with reference to mature security standards in the industry. The products and operation services of FLYINSONO are provided by VINNO Technology (Suzhou) Co., Ltd. VINNO Technology (Suzhou) Co., Ltd. ("VINNO") attaches importance to the personal privacy data you share with us. Please read this privacy policy carefully. It aims to help you understand our privacy practices, including what personal data we collect, why we collect personal data, how we deal with it, how we protect it and your personal rights. VINNO Technology (Suzhou) Co., Ltd. manages the data involved in this privacy policy. This is a statement about VINNO privacy protection measures, not a contract or agreement.

This policy is closely related to the products and / or services that you use, and when you download, install, launch, browse, register, log in, and use our products and / or services, we will treat and protect your personal information in accordance with this policy.

When you use our products and / or services, we may collect and use information about you. To this end, we hope that this Privacy Policy will explain to you how we obtain, use, share, store and manage this information. Please read and fully understand this Policy before using / continuing to use our products and services, and if necessary, make appropriate choices in accordance with the guidelines of this Policy. If you do not agree with the content of this policy, it may cause our products and / or services to fail to function normally, or fail to achieve the service effect we intend to achieve, you should immediately stop accessing / using our products and / or services. Your use or continued use of the products and / or services provided by us indicates that you fully understand and agree to the entire contents of this Privacy Policy (including updated versions).

How we collect your personal information

1.1 You provide personal information to us

1.1.1 In order to use our products and / or services, you first need log in an account and log in. You may choose to create an account and log in to our products and / or services ("Account Login") through email login, etc.

1.1.1.1 After the registration is completed, you can choose to modify or supplement your profile picture, nickname, password and other information (but not providing such information will not affect your use of our products and / or services), which are all your account information. For the personal information involved in such account information, we will protect it in accordance with this privacy policy.

1.1.2 When you use our products and / or services, you may contact our customer service for account management, product use, etc. For this purpose, you may need to provide us with information related to your use of our products and / or services, such as your email, the records and contents of your communications with us, so that our customer service staff can contact you and help you solve your problems. If you refuse to provide this information, we may not be able to help you resolve the issue.

1.2 We collect information about the devices and networks you use

When you use our products and / or services, we will collect information about the equipment you use. In order to provide you with continuous and stable service support, and at the same time help us to continuously improve our products and / or services, so that you can get the best experience in the process of using our products and / or services. The information we collect about the device you use includes the device name, device model, hardware serial number, operating system and application version and type, Language settings, resolution, mobile terminal random storage memory, login IP address, access to the network, network quality data, mobile network information (including operator name), log information (such as operation log, service log) and so on.

1.3 Information Collected from You by Third Parties

1.3.1 In order to improve the user experience and convenience of our products and / or services, we may collect your personal information as follows by invoking device permissions. If you do not agree to provide this personal information, you may not be able to use the features related to improving the user experience, and you may also need to manually re-fill some information in the process of using our products and / or services.

1.3.2 If you wish to upload your profile picture and / or other picture information to FLYINSONO, you may choose to authorize FLYINSONO to access the camera or album permissions on the device you are using.

1.3.3 If you agree to voice interaction in a FLYINSONO Learning course, you may choose to authorize FLYINSONO Learning to call the microphone privileges of the device you are using.

1.3.4 If you wish to implement or experience the above features, you may need to open the corresponding access right in your device. You can also revoke the authorization by turning off the access right at any time. In different devices, the permission display and closing method may be different, please refer to the instructions or guidelines of the device and system developer.

1.4 You are fully aware that under the following circumstances, we do not need to obtain your consent for the collection and use of personal information:

1.4.1 Related to national security and national defense;

1.4.2 Related to public safety, public health, significant public interest;

1.4.3 In connection with the investigation, prosecution, trial and execution of sentences;

1.4.4 For the purpose of safeguarding the important legitimate rights and interests of the personal data subject or other individuals, such as life and property, but it is difficult to obtain their consent;

1.4.5 The personal information collected is disclosed by the personal data subject to the public on his own;

1.4.6 Your personal information collected from lawful public disclosure of information, such as lawful news reports, government information disclosure and other channels;

1.4.7 It is necessary to enter into and perform the contract at your request;

1.4.8 Necessary for the maintenance of the safe and stable operation of the products and / or services provided, such as the detection and disposal of malfunctions of the products and / or services;

1.4.9 Other circumstances prescribed by laws and regulations.

How we use your personal information

After collecting your Personal Information, we will use your Personal Information in accordance with the following rules:

2.1 The personal information collected will be used in accordance with this Privacy Policy and in order to implement the functions of our products and / or services.

2.2 Please note that for all personal information you provide when using our products and / or services, unless you delete or refuse our collection through the relevant settings, you will continue to authorize us to use the products and / or services during the use of our products and / or services.

2.3 When we intend to use your personal information for other purposes not specified in this Policy, or to use information collected for specific purposes for other purposes, we will actively seek your express consent in advance.

How to Share, Transfer and Disclose Your Personal Information

To share

3.1 We will strictly abide by relevant laws and regulations and keep your personal information confidential. We do not share your personal information with others except in the following circumstances:

3.1.1 Obtain your prior express consent or authorization;

3.1.2 In accordance with applicable laws and regulations, or on the basis of a mandatory request by a judicial or administrative authority;

3.1.3 Within the scope permitted by laws and regulations, it is necessary to provide it in order to protect the legitimate rights and interests of life, property, or social public interests of you or other users or other individuals;

3.1.4 With third parties as described in this Privacy Policy;

Transfer the possession of

3.2 We will not transfer your personal information to any company, organisation or individual except in the following circumstances:

3.2.1 Obtain your prior express consent or authorization;

3.2.2 Must be provided in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;

3.2.3 According to the relevant agreement signed with you (including online signed electronic agreement and the corresponding platform rules) or other legal documents;

Public disclosure

3.3 We will only disclose your personal information publicly under the following circumstances, and under the premise of taking security measures in line with industry standards:

3.3.1 Disclose the personal information specified by you in the manner of disclosure you have expressly consented to according to your needs;

3.3.2 In accordance with the requirements of laws, regulations, and mandatory requirements of administrative or judicial authorities, we may disclose your personal information publicly. When we receive the above disclosure request, we will legally require the requesting party to produce relevant legal documents, such as subpoenas or letters of assistance in the investigation. We will carefully review each disclosure request to ensure that such disclosure requests comply with relevant legal requirements. Under the premise of laws and regulations, we will take measures such as encryption protection for documents containing disclosed information.

How to Protect Your Personal Information

4.1 We take personal information security very seriously and will take all reasonably practicable measures to protect your personal information from unauthorized access, alteration or disclosure:

4.1.1 We have adopted industry-standard security measures to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable steps to protect your personal information.

4.1.2 Access to personal information is only allowed to those who are necessary to know, and there is a strict access right control and monitoring mechanism. We also require all persons who may have access to your personal information to comply with applicable confidentiality obligations. Failure to comply with these obligations may result in legal liability or termination of the corresponding legal relationship with us.

4.2 We will take all reasonably practicable steps to ensure that no irrelevant information is collected.

4.3 We declare that we will not make any modification or compilation of the data you upload, except with your express consent.

4.4 Please understand that due to technical limitations and various malicious means that may exist, in the Internet industry, even if we do our best to strengthen security measures, it is not always possible to guarantee 100% absolute security of information. You need to understand and know, the systems and communication networks that you use to access our products and / or services may have problems due to other factors beyond our control, in which case we will do our best to help resolve them according to law.

4.5 If unfortunate information security incidents occur, we will inform you in a timely manner, in accordance with the requirements of laws and regulations: the basic situation and possible impact of security incidents, the disposal measures we have taken or will take, you can independently prevent and reduce the risk of recommendations. At the same time, we will promptly inform you of the relevant circumstances of the incident by email, letter, telephone, push notification and other appropriate means; When it is difficult to inform the data subject one by one, we will publish a notice in a reasonable and effective manner. At the same time, we will also be in accordance with the requirements of the regulatory authorities, take the initiative to report the disposal of information security incidents.

How to Store Your Personal Information

Retention period

5.1 During the period of the user's use of FLYINSONO products and / or services, FLYINSONO will continue to store the user's personal information.

Preservation Area

5.2 All your personal information will be stored in China.

5.3 At present, we do not provide personal information to overseas scenarios.

Managing, Viewing or Deleting Your Personal Information

We respect your rights regarding your personal information. We protect your rights to access, correct, delete and manage your personal information.

Accessing and Correcting Your Personal Information

6.1 Unless otherwise provided by laws and regulations, you have the right to exercise your data access right. When you find that we have made mistakes in the processing of your personal information or you have other amendments or supplements, you also have the right to request us or correct them yourself. Ways in which you exercise your right to access and correct data include, but are not limited to:

6.1.1 If you wish to access or modify your account information in our products and / or services, Including avatars, nicknames, etc., you can operate by visiting our products and / or services (you can operate by clicking "I," entering the personal homepage, and clicking the "Edit" function).

Deletion of your personal information and withdrawal of consent

6.2 In the following circumstances, you may request the deletion of your personal information from FLYINSONO:

6.2.1 If we process personal information in violation of relevant laws and regulations;

6.2.2 If we collect and use your personal information without your consent;

6.2.3 If the processing of personal information violates the agreement with you or the provisions of the law;

6.2.4 If you no longer use the products and / or services of the FLYINSONO;

6.2.5 If we no longer provide products and / or services to you.

6.3 You have the right to withdraw your consent to the collection and use of your personal information. When you withdraw your consent, we will no longer process your personal information. However, your decision to withdraw your consent will not affect the personal information processing activities previously carried out under your authorization.

Deactivate account.

6.4 You can deactivate your account through the following steps:

6.4.1 Click on the profile picture to access the personal center.

6.4.2 Click on "Settings".

6.4.3 Find "About FLYINSONO".

6.4.4 Click on the "Deactivate Account" button next to "Account Deactivation".

6.4.5 Carefully read the "User Account Deactivation Agreement" and confirm the deactivation.

6.5 When you deactivate your account, we will verify your identity and may collect your phone number and email information (which will not include sensitive personal information). We will not collect any information beyond what you provided during registration and usage of the account.

6.6 After you cancel your account,unless provided by relevant laws and regulations,otherwise we will delete or anonymize your personal information with in 15 workdays

6.7 VINNO is not responsible for security omissions caused by third-parties obtaining your personal information due to your failure to keep your personal information confidential. Not with standing the foregoing,you must immediately notify us of any unauthorized use of your account or anyother breach of security by anyother Internet users.

Other

7.1 Any dispute arising from this Policy and our handling of your personal information may be brought to the People's Court of Suzhou Industrial Park.

7.2 If you think that our personal information processing behavior damaged your legitimate rights and interests, you can also report to the relevant government departments.

7.3 The posting of this Privacy Policy by us or the provision of products and / or services to you shall be deemed to be effective. This Privacy Policy will expire when we cease to operate or permanently cease to provide products and / or services.

- Changes to this Privacy Policy

The services provided by VINNO are constantly being improved and the form and nature of the services may be adjusted at any time without notice. Therefore, we reserve the right to modify or supplement this Privacy Policy at any time.

The new privacy policy will be effective upon posting, and if you do not agree with the revised policy, then please consider stopping using the app. By continuing to use, after these changes become effective, you agree to be bound by the revised Privacy Policy.

- Contact Us About Us

If you have any questions, complaints or suggestions about this privacy policy, please contact us at: 4008873806.