Privacy Policy

AVI9 PRIVACY POLICY

Effective Date: 9 July 2026

Last Updated: 17 June 2026

This Privacy Policy explains how AVI9 collects, uses, stores, shares and protects personal data when you use the AVI9 website, mobile application, platform and related services collectively referred to as the "Services".

AVI9 is operated by:

Pulsar Global Holdings Limited

Company Registration No.: 80327391-000-05-26-A

Registered Address: UNIT 903D, 9/F., CAMERON COMM CENTRE, 458-468 HENNESSY ROAD, CAUSEWAY BAY, HONG KONG

Privacy and Support Email: support@avi9.club

In this Privacy Policy, "AVI9", "we", "us" and "our" refer to Pulsar Global Holdings Limited.

For applicable data protection laws, Pulsar Global Holdings Limited is generally the controller or data user responsible for determining how and why your personal data is processed.

1. Scope

This Privacy Policy applies when you:

• Visit an AVI9 website;
• Download or use an AVI9 application;
• Create or manage an account;
• Search for merchants and offers;
• Use Map View or location-based features;
• Apply for aviation professional verification;
• Submit or suggest a merchant;
• Contact AVI9 support;
• Communicate with us;
• Participate in a survey, promotion or platform programme;
• Use other AVI9 features.

Merchant websites, external booking systems, map providers and other third-party services have their own privacy practices. This Privacy Policy does not govern information independently collected by those third parties.

2. Personal Data We Collect

The data we collect depends on how you use the Services.

2.1 Account and Contact Information

We may collect:

• Full name;
• Email address;
• Telephone number;
• Country or region;
• City;
• Profile photograph;
• Login credentials;
• Account preferences;
• Preferred language;
• Communications with AVI9.

2.2 Aviation Employment and Verification Information

To verify eligibility for aviation-industry offers or features, we may collect:

• Airline, airport, employer or aviation organisation;
• Job title, role or department;
• Employment status;
• Home base;
• Work email address;
• Staff or employee identification number;
• Employment start or expiry information;
• Photograph or copy of a staff card, aviation employee card or other evidence;
• Verification status and verification history;
• Information submitted in connection with an appeal or re-verification.

Please avoid submitting information that is not necessary for verification. Where appropriate, you may redact unrelated information before uploading a document.

AVI9 verification is for platform eligibility only. It is not an official security, immigration, airport-access or government verification process.

2.3 Location Information

With your device permission, we may collect or process:

• Approximate location;
• Precise device location;
• Country, city or district selected by you;
• Location used to identify nearby merchants;
• Location associated with Map View or search results.

Depending on your device settings and the feature being used, AVI9 may request your current location when you log in or use a location-based feature.

You can deny or withdraw location permission through your device settings. Some location-based features may then be unavailable or less accurate.

We do not use location information for aircraft tracking, crew operational monitoring or safety-critical aviation decisions.

2.4 Merchant Search and Usage Information

We may collect:

• Search terms;
• Countries, cities, districts and categories selected;
• Merchants and offers viewed;
• Map interactions;
• Favourites or saved merchants;
• Links or contact buttons selected;
• Time and frequency of use;
• Feature interactions;
• Referral pages and navigation information.

2.5 Merchant Suggestions and Submitted Content

When you suggest a merchant or submit platform content, we may collect:

• Merchant name;
• Country, city, district or location;
• Merchant category;
• Google Maps link;
• Website or social-media link;
• Merchant contact information;
• Images;
• Your reason for making the suggestion;
• Submission status;
• Communications relating to the submission.

2.6 Device and Technical Information

We may automatically collect:

• IP address;
• Device type;
• Operating system;
• Browser type;
• App version;
• Device identifiers;
• Language and time zone;
• Crash reports;
• Security logs;
• Authentication activity;
• Cookie and similar-technology information;
• General network and diagnostic information.

2.7 Support and Communications

When you contact us, we may collect:

• Your contact details;
• Message content;
• Screenshots or files provided by you;
• Complaint or request details;
• Support history;
• Records of our response.

2.8 Merchant and Business Representative Information

For merchant representatives or business partners, we may collect:

• Name and job title;
• Company name;
• Business email and telephone number;
• Commercial registration or licence details;
• Merchant location and branch details;
• Offer and discount information;
• Contract and signature information;
• Communications and approval records.

2.9 Information from Third Parties

Where permitted by law, we may receive information from:

• Merchants;
• Aviation employers or organisations involved in verification;
• Authentication providers;
• Map and location providers;
• Analytics and security providers;
• Business partners;
• Publicly available business sources;
• Other users submitting merchant information.

We do not require an employer to disclose more information than is reasonably necessary to confirm eligibility.

3. Mandatory and Optional Information

Some information is required to:

• Create an account;
• Authenticate your identity;
• Verify aviation eligibility;
• Provide a requested feature;
• Respond to a legal or support request;
• Protect the platform against fraud.

Required fields will normally be identified in the relevant form.

If you do not provide required information, we may be unable to create or verify your account, provide the requested feature or process your request.

Optional information may help personalise or improve your experience but is not required for basic access unless otherwise stated.

4. How We Use Personal Data

We may use personal data to:

• Create and manage accounts;
• Authenticate users;
• Verify aviation professional eligibility;
• Display an AVI9 verification status;
• Provide merchant, offer, search and Map View features;
• Identify nearby merchants where location permission is enabled;
• Personalise search results and recommendations;
• Process merchant suggestions;
• Communicate with users, merchants and partners;
• Provide customer support;
• Investigate complaints;
• Detect fraud, forged documents and account sharing;
• Protect users, merchants and the Services;
• Monitor platform performance;
• Correct errors and improve functionality;
• Conduct analytics and product research;
• Enforce our Terms and Conditions;
• Maintain legal, security and operational records;
• Comply with law, court orders and regulatory requirements;
• Establish, exercise or defend legal claims;
• Send service notices and, where permitted, marketing communications.

We will not use personal data for an unrelated new purpose without an appropriate legal basis, notice or consent where required.

5. Legal Bases for Processing

Where applicable law requires a legal basis, we process personal data on one or more of the following grounds:

5.1 Contractual Necessity

Processing may be necessary to provide the Services you request, manage your account and perform our obligations under the Terms and Conditions.

5.2 Consent

We may rely on your consent for:

• Precise location access;
• Non-essential cookies or similar technologies;
• Certain marketing communications;
• Optional profile information;
• Other processing where consent is required.

You may withdraw consent at any time. Withdrawal does not affect processing lawfully completed before withdrawal.

5.3 Legitimate Interests

Where permitted, we may process data for legitimate interests such as:

• Operating and improving AVI9;
• Securing accounts;
• Preventing fraud;
• Verifying eligibility;
• Maintaining accurate merchant information;
• Understanding service usage;
• Protecting AVI9, users and merchants;
• Managing business operations.

We consider the effect of such processing on your rights and interests.

5.4 Legal Obligations

We may process data to comply with laws, regulatory requirements, lawful requests and legal proceedings.

5.5 Protection of Rights

We may process data where necessary to establish, exercise or defend legal claims or protect the rights and safety of AVI9, users, merchants or others.

6. Aviation Verification Documents

Verification documents may contain sensitive employment or identification information.

We limit access to authorised personnel and service providers who require access for verification, fraud prevention, security, legal compliance or dispute handling.

We retain verification documents only for as long as reasonably necessary for the purpose for which they were collected, including completing verification, preventing repeated fraud, handling appeals or disputes and meeting legal requirements.

Where reasonably possible, we may retain a verification result and limited supporting metadata rather than keeping the full document indefinitely.

Do not submit passports, national identity cards, financial information or unrelated personal records unless AVI9 specifically requests them and there is a valid reason.

7. Location Data

Location access is controlled through your device permissions.

We may use your location to:

• Determine your current country or city;
• Show nearby merchants;
• Calculate approximate distance;
• Support Map View;
• Improve location-based search results;
• Detect unusual or fraudulent platform activity.

We do not continuously track your precise location when the relevant feature is not active unless we separately notify you and obtain any required permission.

Location results may be inaccurate because of device, network or third-party map limitations.

8. Automated Recommendations and Ranking

AVI9 may use automated systems to rank merchants, offers or search results based on factors such as:

• Selected country or city;
• Current or chosen location;
• Merchant category;
• Distance;
• Popularity;
• Availability;
• User preferences;
• Search activity.

These systems are intended to improve discovery. They are not used to make legal, employment, immigration, credit or similarly significant decisions about you.

9. Marketing Communications

We may send service-related communications that are necessary for your account, including:

• Verification notices;
• Security alerts;
• Changes to the Terms or Privacy Policy;
• Important service updates;
• Responses to support requests.

Where permitted and with any required consent, we may also send information about:

• New AVI9 features;
• Merchant offers;
• Promotions;
• Relevant aviation lifestyle benefits;
• Platform announcements.

You may opt out of marketing communications at any time by:

• Using the unsubscribe link in the message;
• Changing available account preferences;
• Emailing support@avi9.club.

Opting out of marketing does not prevent us from sending essential account, legal or security communications.

We will not charge you for making a marketing opt-out request.

10. Cookies and Similar Technologies

AVI9 and its service providers may use cookies, local storage, software development kits, pixels and similar technologies to:

• Keep you signed in;
• Remember preferences;
• Protect account security;
• Measure usage;
• Detect errors;
• Improve performance;
• Understand how users interact with the Services.

Where required by law, we will request consent before using non-essential cookies or technologies.

You may control certain technologies through your browser, device or cookie settings. Disabling them may affect functionality.

11. When We Share Personal Data

We may share personal data with the following categories of recipients.

11.1 Service Providers

We may use service providers for:

• Cloud hosting;
• Database storage;
• Authentication;
• Email delivery;
• Customer support;
• Analytics;
• Security and fraud prevention;
• Document verification;
• Maps and location;
• Software development and maintenance.

These providers may process data only for authorised purposes and subject to appropriate contractual or legal obligations.

11.2 Merchants

We do not routinely disclose your AVI9 profile to a merchant merely because you view its listing.

Information may be shared with a merchant where:

• You contact the merchant through AVI9;
• You request a booking or service requiring data transmission;
• A redemption feature requires confirmation;
• You expressly authorise the sharing;
• Sharing is reasonably necessary to investigate fraud or misuse.

A merchant may independently request to see your aviation employment identification when you redeem an offer. Information shown directly by you to a merchant is handled by that merchant under its own privacy responsibilities.

11.3 Aviation Employers or Organisations

Where reasonably necessary and legally permitted, we may contact an aviation employer or organisation to verify eligibility, investigate suspected forged documents or address serious misuse.

We will seek to limit the information disclosed to what is necessary for the verification or investigation.

11.4 Professional Advisers

We may share information with lawyers, accountants, auditors, insurers or other professional advisers where necessary for legitimate business or legal purposes.

11.5 Authorities and Legal Requests

We may disclose information where we reasonably believe disclosure is necessary to:

• Comply with applicable law;
• Respond to a court order or lawful request;
• Investigate fraud or unlawful activity;
• Protect the safety or rights of users, merchants or others;
• Enforce our agreements;
• Establish, exercise or defend legal claims.

11.6 Corporate Transactions

Personal data may be disclosed or transferred in connection with a proposed or completed merger, financing, restructuring, acquisition, sale of assets or transfer of the AVI9 business.

Any recipient will be required to use personal data consistently with applicable law and this Privacy Policy or provide appropriate notice of changes.

12. International Data Transfers

AVI9 operates as a global platform. Personal data may be processed or stored in Hong Kong or other jurisdictions where our service providers, contractors or business operations are located.

Privacy laws in another jurisdiction may differ from those in your country.

Where required, we use appropriate measures for international transfers, which may include:

• Contractual data-protection clauses;
• Transfer agreements;
• Access and security restrictions;
• Processing instructions;
• Other legally recognised safeguards.

By using the Services, you understand that international processing may be necessary to operate a global platform, subject to applicable legal protections.

13. Sale of Personal Data

AVI9 does not sell personal data for monetary consideration.

We do not provide aviation verification documents to merchants or advertisers for their independent marketing use.

If our practices materially change, we will update this Privacy Policy and provide any notice, consent or opt-out rights required by law.

14. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or for a directly related purpose, including:

• Providing and maintaining your account;
• Verifying eligibility;
• Preventing fraud and abuse;
• Maintaining security records;
• Resolving disputes;
• Enforcing agreements;
• Meeting legal, tax, accounting or regulatory requirements.

Retention periods depend on the type of information and the reason it is held.

For example:

• Account information may be retained while your account remains active and for a reasonable period after closure;
• Verification information may be retained while necessary to maintain verification and prevent fraud;
• Support and complaint records may be retained for dispute and quality-control purposes;
• Security logs may be retained for a limited period appropriate to security risks;
• Backup copies may remain temporarily until overwritten under normal backup schedules.

When personal data is no longer required, we will take reasonable steps to delete, anonymise or securely isolate it, unless retention is required or permitted by law.

15. Security

We use reasonable administrative, technical and organisational measures designed to protect personal data against:

• Unauthorised access;
• Accidental loss;
• Improper disclosure;
• Alteration;
• Destruction;
• Misuse.

Measures may include access controls, authentication, encryption where appropriate, monitoring, staff restrictions and service-provider obligations.

No internet transmission or storage system is completely secure. You are responsible for protecting your password, device and account access.

Notify us promptly at support@avi9.club if you believe your account or personal data has been compromised.

Where required or appropriate, we will assess data-security incidents and notify affected individuals or relevant authorities.

16. Your Privacy Rights

Depending on your location and applicable law, you may have rights to:

• Request access to personal data held about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of certain personal data;
• Request restriction of processing;
• Object to certain processing;
• Withdraw consent;
• Request a portable copy of certain information;
• Opt out of direct marketing;
• Ask for information about how your data is used;
• Complain to an applicable data-protection authority.

These rights may be subject to legal conditions, exemptions and identity verification.

To exercise a right, email support@avi9.club with:

• Your name;
• Your registered email address;
• The right or request involved;
• Sufficient information to identify the relevant records.

We may request reasonable proof of identity before processing a request.

We will not discriminate against you for exercising a privacy right.

17. Account Deletion

You may request deletion of your AVI9 account through available account settings or by emailing support@avi9.club.

Account deletion may result in the loss of:

• Verification status;
• Saved merchants;
• Profile information;
• Preferences;
• Submission history;
• Access to account-only features.

We may retain limited information after deletion where reasonably necessary for fraud prevention, legal compliance, security, dispute resolution or enforcement of our Terms.

Content that has been anonymised or incorporated into a merchant business listing may not identify you and may remain on the platform.

18. Children

AVI9 is intended for adults aged 18 or older.

We do not knowingly collect personal data from children under 18.

If you believe a child has provided personal data to AVI9, contact support@avi9.club. We will review the report and take appropriate action.

19. Third-Party Links and Services

The Services may contain links to merchants, maps, social-media platforms, websites, booking systems and other third-party services.

Those third parties may independently collect information from you.

Their collection and use of information are governed by their own privacy policies, not this Privacy Policy.

Review the relevant third-party privacy policy before providing personal data.

20. Complaints

Privacy questions and complaints may be sent to:

Email: support@avi9.club

We will review legitimate complaints and respond within a reasonable period.

Depending on your location, you may also have the right to complain to a privacy or data-protection regulator, including the Office of the Privacy Commissioner for Personal Data in Hong Kong or the competent regulator in your country.

21. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in:

• The Services;
• Data practices;
• Legal requirements;
• Security measures;
• Technology;
• Business operations.

The revised policy will show a new "Last Updated" date.

Where changes materially affect your rights or how personal data is used, we will provide appropriate notice and obtain consent where required.

22. Language

This Privacy Policy may be made available in multiple languages.

Where legally permitted, the English version will prevail if there is an inconsistency between translations.

23. Contact Information

For privacy requests, account deletion, complaints or questions, contact:

Pulsar Global Holdings Limited

AVI9 Privacy and Support Team

Email: support@avi9.club

Address: UNIT 903D, 9/F., CAMERON COMM CENTRE, 458-468 HENNESSY ROAD, CAUSEWAY BAY, HONG KONG