1. Privacy Statement
Xi’an ANZ International Travel Service Co., Ltd (“we”, “our”, “us”) consider your privacy to be important and take our responsibility to protect it seriously. We understand that you are concerned about your privacy, along with the confidentiality and security of any personal information that you provide to us.
This privacy policy (Policy) sets out how we collect, hold, use and disclose information about individuals who deal or interact with us. We treat all personal information collected by us in accordance with relevant Privacy Laws. If there is any inconsistency between the Privacy Laws and this Policy, the Privacy Laws will prevail to the extent of the inconsistency.
2. Collecting personal information
2.1 General
Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. We store personal information that is provided to us as a part of our business, or that is provided to us through the use of our products and services.
Due to the nature of the services we provide it is generally impractical for us to deal with you without knowing your name and your contact details. However, where it is practical for us to do so, we shall provide you with the option to deal with us anonymously or by using a pseudonym.
We collect personal information from a wide variety of sources including:
(a) through our website www.chinatours.com (the Site);
(b) from you contacting us and conducting business with us;
(c) from your company, employers and managers with whom we are dealing;
(d) by you otherwise interacting with us, whether by telephone, email, ordinary mail or any other electronic or online means; and/or
(e) through any of our other business activities or events.
Personal information collected by us may include your:
(a) full name;
(b) contact details such as mobile number, telephone number and email address;
(c) gender;
(d) physical or residential address;
(e) information gathered from passports supplied by you;
(f) information gathered from payment transactions, for example paypal, credit card, supplied by you; and
(g) all logs, which may include information such as your internet protocol (IP) address, browser type, browser version, clickstream data, referring URLs, the pages of our Site that you visit, the time spent on any pages of our Site or Platform and other log related information relating to your use of our Site or Platform.
We endeavour to only collect personal information where it is reasonably required.
2.2 Sensitive personal information
Some personal information, including health information, is sensitive and requires a higher level of protection. We will only collect such sensitive information when we have your consent for us to do so and the collection is reasonably necessary:
(a) for us to:
(i) provide our products or services;
(ii) pursue one or more of our functions or activities;
(b) as required or authorized by law;
(c) for the establishment, exercise or defence of a legal claim.
For the purpose of clarity, the provision of your sensitive information shall constitute your consent for us to collect and use such information contemplated by this Policy.
3. Use of personal information
We automatically gather information to monitor the provision of our other products and services and your use of our Site. Much of the data we collect is aggregated and anonymous to us.
In general, we use personal information for providing, evaluating, improving, personalising and developing our business, our Site and our associated products and services.
More specifically we use personal information:
(a) for establishing and maintaining your relationship as our customer;
(b) for providing any products and services you have requested from us;
(c) to enable you to access and use the products, services, the Site and applications provided by us or any of our related agents, suppliers, contractors and merchants;
(d) to request, book and confirm products and services from us and any of our related agents, suppliers, contractors and/or merchants;
(e) for administering and managing products and services provided to you;
(f) to operate, protect, improve and optimize products, services, the Site, applications, business or user experience of us and any of our related agents, suppliers, contractors or merchants including to perform analytics, conduct research and for advertising and marketing;
(g) for answering your inquiries and providing you support;
(h) for improving user satisfaction, particularly with regard to our Site including to personalize your visits to our Site and developing the design and style of our Site to improve the products and services provided to you;
(i) for informing you about the latest changes to our products, services or Site or promotional offers which we believe may be of interest to you;
(j) to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us;
(k) for communicating, and personalizing such communication, with you;
(l) for promoting and marketing our services to you (each person may opt-out of direct marketing and sales communications);
(m) to send you service, support, administrative messages, reminders, technical notices, updates and security alerts and information requested by you;
(n) to enable you to share our Site content with others e.g. by using an ‘Email a friend’ or ‘Share this’ functionality’ feature;
(o) for our internal research and statistical purposes;
(p) for carrying out technical and statistical analysis to measure the performance of our products, services and our Site
(q) for enabling us to forward to you other information or material which we believe may be of interest to you (each person may opt-out of our information sharing communications); and
(r) to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
If we believe we need to use your personal information, other than as contemplated by this clause, we will only use your personal information if you consent to it.
4. Disclosure of personal information
We may disclose personal information for the purposes described in this Policy to:
(a) our employees, related agents and contractors;
(b) our third-party suppliers, merchants and service providers (including providers for the operation of our Sites or our business or in connection with providing our products and services;
(c) professional advisers and agents;
(d) payment systems operators (e.g. merchants receiving card payments);
(e) our existing or potential agents, business partners or partners;
(f) our sponsors or promoters of any competition that we conduct via our services;
(g) anyone to whom our assets or businesses (or any part of them) are transferred;
(h) specific third parties authorized by you to receive information held by us;
(i) the China National Tourism Administration (China Government Department) for statistical purposes; or
(j) third parties in accordance with clause 7.
Aside from the above, we will only disclose personal information as legally required – either upon valid court order, as required under the Privacy Laws, or where compelled by a law enforcement or governmental agency.
5. Protecting your personal information
5.1 Steps we take
We take reasonable steps to protect personal information we hold from:
(a) misuse, interference and loss; and
(b) unauthorized access, modification or disclosure.
The precautionary steps we take to protect personal information include:
(a) adopting appropriate and up-to-date technological protection measures to protect our computer systems and networks for storing, processing and transmitting personal information;
(b) adoption of procedural and personnel measures for limiting access to personal information by our staff;
(c) reviewing our information collection, storage and processing practices; and
(d) such other security measures we consider reasonable and appropriate from time to time.
Notwithstanding that we use our best endeavours to protect all personal information we collect and hold, please be aware that we unfortunately cannot guarantee its complete security and will not be responsible where it is obtained by illegal third-party actions.
5.2 Deleting your personal information
When personal information is no longer required to be kept by us, we will take reasonable steps (taking into account any contractual/legal obligations that we are required to comply with) to destroy or delete the personal information in a confidential manner.
6. Cookies
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some features of our products and services.
7. Third-party disclosure
7.1 Disclosure for analytics
We may use Google Analytics to track your usage of our Site. Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the website, to prepare reports on the site’s activities and share them with other Google services.
Google may use the data collected to contextualize and personalize the ads of its own advertising network. Personal data collected by Google includes cookie and usage data, which is processed in the United States of America. You can find Google’s privacy policy here: http://www.google.com.au/policies/privacy/.
7.2 Storing data
We store all personal information that we collect on cloud servers that may located in various locations throughout the world including the United States of America. We may store information in multiple locations for both security and resiliency purposes.
If you are located outside of China and choose to provide your personal information to us, your personal information will be transferred to China and processed in accordance with this Policy.
7.3 Trusted third-party
We may also disclose your personal information to a trusted third-party who also holds other information about you. This third-party may combine your information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalize your experience and enhance the products and services that we believe may be of interest to you.
7.4 Consent to third-party disclosure
Other than as contemplated in this clause 7, we will only disclose your personal information to a third-party recipient if:
(a) you consent to the transfer; or
(b) the disclosure of the information is required or authorized by or under an applicable law or a court/tribunal order.
We will take reasonable steps to ensure such third-party recipients do not breach any applicable Privacy Laws.
8. Third-party sites
Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites, products or services whatsoever.
You should be aware that your ability to opt-out of a third-party tool or platform will depend on the conditions governing your agreement with that third-party.
9. Accessing and updating your personal information
9.1 Access to Personal Information
We will provide you with access to your personal information held by us unless:
(a) giving access would be unlawful;
(b) giving access would result in a breach of our contractual obligations to another party; or
(c) denying access is required under the Privacy Laws or any other applicable law.
9.2 Request for Access
If you would like access to your personal information aside from your account information, you must contact us in writing making such a request. You may contact us via email at [email protected]. Following receipt of your request, we will contact you and either provide you with the information you have sought or return to you with an explanation detailing why we will not provide you with the information.
9.3 Amending your personal information
If you wish to amend personal information that we hold, please contact us to request the amendment. You may contact us via email at [email protected]. If we elect not to correct your information, we will notify you, within a reasonable time, of the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters required by the Privacy Laws.
If you wish to have your personal information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
10. Complaints
We strive to ensure our compliance with this Policy and to regularly review our practices against it.
If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Laws, we invite you to make a complaint at [email protected]. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution to the issue raised.
11. Variations
We reserve the right to vary this Policy from time to time. Any variations made will be updated on our Site and Platform. It is your responsibility to check our Policy periodically to ensure you are aware of any changes made to it.
12. Contact us
For any further information about this Policy please contact us at [email protected].
