Privacy Policy

The type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf. For example, we may collect details such as your name, residential/mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), passport details, loyalty program / frequent flyer details, information about your dietary requirements and health issues (if any), and other details relevant to your travel arrangements or required by the relevant travel service provider(s) (e.g. airlines and accommodation or tour providers).

In some circumstances, we may collect personal information from you which may be regarded as sensitive information under your local data protection laws. Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, health information… We will only collect sensitive information in compliance with your local data protection laws, with your consent and/or where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorized to do so by law. To the extent permitted or required under your local data protection laws, you consent to us using and disclosing your sensitive information for the purpose for which it was collected, unless we subsequently receive your consent to use it for another purpose. We will not use sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.

We will collect personal information directly from you unless it is unreasonable or impracticable to do so. Generally, this collection will occur when you deal with us either in person, by telephone, email, when you visit any of our websites or when you connect with us via social media. We may collect personal information about you when you purchase or make enquiries about travel arrangements or other products and services; or when you provide information, or use our services, on social media. Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.

In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveler on the booking. By providing your personal information to us, either directly or through a family member, employer or other agent or representative in connection with a travel booking or related service, you will be deemed to have consented to your personal information being collected by us and used and disclosed in accordance with this Policy.

You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.

We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.

By providing personal information to us (either directly or allowing another person to do so on your behalf), you agree that this Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Policy. If you do not agree with any part of this Policy, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Policy, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveler’s full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.

1. When we act as agent for a travel service provider?

When we book and otherwise arrange travel related products and services for you, we usually do so as agent for or on behalf of travel service providers. In this case, we usually collect personal information about you both for our internal purposes as described in this Policy, including the purpose of us processing your booking, and for the travel service provider for whom we act as agent for their internal purposes. As an agent, all bookings are made on your behalf subject to the terms and conditions, including privacy policy, imposed by these travel service providers. We will provide you with copies of all relevant travel service provider terms, conditions and privacy policies on request.

Accordingly, you are deemed to consent to the collection, use and disclosure of your personal information by us to the relevant travel service providers, and the use and disclosure of your personal information by the relevant travel service providers, for the purposes set out in this Policy and, to the extent permitted under your local data protection laws, for other purposes specified in their privacy policy. For example, if you book accommodation through us, then under this Policy you consent to us collecting your personal information and disclosing that information to the accommodation provider to enable your hotel to be booked and for the accommodation provider to provide the service to you, and, to the extent permitted under your local data protection laws, for other purposes specified in their privacy policy.

2. How do we use and disclose your personal information?

Where you contact us in relation to a travel booking or query, the primary purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Policy.

The purposes for which we collect personal information, and those secondary purposes which we consider to be directly related, include:

• Providing you with services (for example, saving travel preferences on our website(s) to a wish list or saving personal information to allow for pre-population of online forms)
• Developing and improving our products and services and those of our related entities
• Servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences
• Involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided
• To facilitate your participation in loyalty programs
• For research and analysis in relation to our business and services
• Internal accounting and administration;
• To comply with our legal obligations and any applicable customs/immigration requirements relating to your travel
• Other purposes as authorized or required by law (e.g. to prevent a threat to life, health or safety, or to enforce our legal rights)
• Promotional/ marketing material

3. Is personal information disclosed to third parties?

We may disclose your personal information to third parties, as set out below, and in accordance with your local data protection laws. Note that, in this Policy, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.

Your personal information may be disclosed to the following types of third parties:

• Our suppliers and service providers, including without limitation:
• Suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting provider(s) we may use);
• Publishers, printers and distributors of marketing material;
• Marketing, market research, research and analysis and communications agencies;
• External business advisers (such as lawyers, accountants, auditors and recruitment consultants);
• Travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
• When you engage us to book flights on your behalf, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant airline. This enables airlines to advise passengers of irregular flight operations and disruptions (e.g. flight cancellations, schedule changes) directly.
• A prospective purchaser, in connection with a merger, acquisition, reorganisation or sale of us.
• A person making your travel booking on your behalf, where you are traveling on a booking made on your behalf by another person (for example, a family member, friend or colleague);
• Your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or traveling for work purposes;
• A person who can verify to us that they have a relationship with you (e.g. a family member) where you are not contactable, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
• As required or authorized by applicable law, and to comply with our legal obligations;
• Customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
• Government agencies and public authorities, to comply with a valid and authorized request, including a court order or other valid legal process;
• Various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
• Enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
• Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorized or required by law (including applicable privacy / data protection laws).

We will not retain your information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of information. However, the longest we will normally hold any personal information is 10 years.

Our websites and mobile applications may use social media features and widgets (such as “Like” and “Share” buttons/widgets). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. 

If you are logged into your account with the third-party companies, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them. Similarly, your interactions with the SM Features may be recorded by the third party. In addition, the third parties company may send us information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third parties company for the purposes of serving targeted marketing to you via the third party social media platform. You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third-party social media platform. For more information about the data practices of these third party-companies, and to find out more about what data is collected about you and how the third parties uses such data, please refer to their privacy policy directly.

When you access our website, use any of our mobile applications or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet. Alone, IP addresses are not personal information, as any one computer or device may be used by multiple people (i.e. it is not possible to ascertain the identity of a user simply from the computer or device being used).

We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (e.g. to better tailor our marketing and advertising materials, provided you have opted in to receive electronic marketing).

Our websites may contain links to third party websites over which we have no control. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policies of any linked third-party websites you visit as their privacy policy and practices may differ from ours.

If you have any enquiries, comments or complaints about this Policy or our handling of your personal information, please contact your consultant or contact us at:

• Email: xinchaolocals@gmail.com
• Tel:
  • Hazel: +84 917805614          
  • Loc:    +84 989600511

We will respond to any enquiries or complaints received as soon as practicable.

We may update and/or alter this Policy from time to time. If we make a change to the Policy, the revised version will be posted on our website at Xin Chao Locals and immediately replaced any previous versions. 

Last updated in *** Oct, 2020