Effective Date: 2026
This Privacy and Pixel Notice (the “Notice”) sets out how China Merchants International Travel Agency Group (“we”, “us”, or “our”) collects, uses, processes, stores, discloses, and protects the personal data of guests and website users (“you” or “your”). This Notice applies to all websites, official social media pages, booking channels, customer services, and private tour services operated by China Merchants International Travel Agency Group.
By accessing our website, submitting inquiries, completing bookings, and using our travel services, you acknowledge that you have read, understood, and agreed to the data processing practices set out in this Notice.
Ⅰ. How Data is Collected
1. Information you provide to us
China Merchants International Travel Agency Group collects Guest Personal Data that you voluntarily provide when you browse our official websites, contact our reservation and customer service teams, consult travel products, book private tours, communicate with our sales and service representatives, or purchase any of our travel and customized services.
2. Information collected automatically
We automatically collect Guest Personal Data generated when you access our official websites, use our on-site Wi-Fi during your tour arrangements, or interact with our online services. Collected information includes device details, IP address, browsing records, website access preferences, and historical inquiry or booking behaviour.
We also use pixel tags, web beacons, and similar tracking technologies to collect non-confidential browsing data to optimize website operation and user experience. Please refer to the Pixel Notice section at the end of this document for full details.
3. Information we obtain indirectly from third parties
We may receive your Guest Personal Data from authorized third-party partners, including official travel agents, tourism service providers, cooperative marketing platforms, ad networks, social media platforms, and official promotion channels.
When you enquire or book our customized tour products through our authorized partners, relevant personal information will be shared with us for order confirmation, service arrangement, and after-sales follow-up. We may also obtain public interactive data from social media platforms where you engage with our official accounts or travel content.
4. Minors Privacy Protection
China Merchants International Travel Agency Group attaches great importance to the privacy protection of minors. Our official websites and commercial services are not targeted at individuals under the age of 18 (“minors”).
We do not knowingly collect personal information from minors without the explicit consent of their parent or legal guardian. Minors are requested to contact our customer service only through their guardians and shall not independently submit personal information or register for website services.
If we confirm that we have unintentionally collected personal data from a minor, we will immediately delete the relevant information from our official records. If you identify any minor data collected by our platform without authorization, please contact our privacy team via our official email address for immediate disposal.
Ⅱ. Categories of Guest Personal Data and Purpose for Processing
We collect and process the following categories of Guest Personal Data strictly based on business necessity, for the purpose of providing standardized and customized private tour services, complying with legal obligations, optimizing user experience, and conducting legitimate business operations.
1. Basic Identity Information
Data Category: Full name, first name and last name, nationality, date of birth, age, gender, passport information, government-issued ID details
Processing Purpose:
· Verify user identity and complete real-name registration and attraction ticket reservation;
· Confirm tourist qualification and ensure compliance with scenic spot entry regulations;
· Complete travel service filing and meet legal supervision requirements;
· Establish effective user communication and service files.
2. Personal Preference & Characteristic Information
Data Category: Travel preferences, scenic spot selection habits, dietary preferences, travel style preferences, personal interests, and crowd attributes (family travel, senior travel, couple travel, group travel)
Processing Purpose:
· Customize exclusive private tour itineraries matching your travel needs;
· Optimize service details and improve overall travel experience;
· Conduct legitimate user profiling for accurate service recommendation;
· Upgrade website functions and travel product systems.
3. Contact Information
Data Category: Mobile phone number, email address, residential or accommodation address, emergency contact information
Processing Purpose:
· Confirm booking information, notify itinerary adjustments, and provide real-time travel reminders;
· Deliver after-sales service follow-up and user satisfaction surveys;
· Send optimized travel recommendations and service updates (with user opt-in consent);
· Contact emergency contacts in case of unexpected travel situations.
You may unsubscribe from marketing messages at any time by clicking the unsubscribe link in emails or replying “STOP” to SMS notifications.
4. Financial & Transaction Information
Data Category: Payment records, transaction amounts, refund records, and relevant billing information
Processing Purpose:
· Complete order payment confirmation, refund processing, and service settlement;
· Prevent transaction fraud and ensure fund security;
· Retain financial records in compliance with tax and regulatory requirements.
5. Account & Authentication Information
Data Category: Website login account, password, and verification records
Processing Purpose:
· Verify user login authority and protect account security;
· Prevent illegal login, fraud, and unauthorized access;
· Maintain normal operation of website service functions.
6. Health & Travel Safety Information
Data Category: Physical health conditions, dietary allergies, medication instructions, and special physical adaptation requirements
Processing Purpose:
· Arrange safe and suitable travel routes for seniors, children, and special groups;
· Avoid travel risks caused by physical conditions or dietary taboos;
· Provide timely assistance and emergency response during travel;
· Comply with scenic spot safety management specifications.
7. Device & Behaviour Data
Data Category: IP address, device model, browser type, website browsing track, page stay time, inquiry and click behaviour
Processing Purpose:
· Ensure website access security and prevent malicious attacks;
· Analyse website operation data and optimize page experience;
· Deliver targeted and accurate travel service recommendations;
· Improve advertising and marketing effectiveness within legal scope.
8. Third-Party Sourced Information
We may obtain authorized user data from cooperative travel agents, marketing platforms, and social media channels to complete order verification, itinerary arrangement, and user background confirmation, ensuring the smooth progress of customized travel services.
9. Guest Profiles
To provide personalized travel solutions, we may integrate and analyse your booking records, service usage records, website browsing behaviour, consultation content, and user feedback to establish exclusive Guest Profiles. All profile data is processed strictly for service optimization and legitimate operation, without unauthorized commercial leakage.
10. Special Category Personal Data
In the process of providing customized group and private tour services, we may involuntarily obtain special category personal data, including dietary taboos, religious beliefs, physical health conditions, and special living habits submitted by users or group booking organizations.
Such data is only used for travel arrangement, risk avoidance, and personalized service matching. You have the right to refuse the provision of sensitive data. Please note that refusal to provide necessary sensitive data may affect the normal arrangement of your travel services and result in the inability to perform booking contracts.
You may withdraw your consent for sensitive data processing at any time. Withdrawal of consent that affects service performance will be deemed as voluntary booking cancellation, and relevant cancellation rules shall prevail.
Ⅲ. Legal Grounds for Data Processing
We process your Guest Personal Data based on the following legitimate legal grounds:
· Performance of Contract: Necessary data processing to complete travel booking, itinerary arrangement, service delivery, and after-sales support;
· Legitimate Interests: Normal business operation, website optimization, service improvement, security risk prevention, and legitimate marketing promotion;
· User Consent: Processing of special category sensitive data and commercial marketing information based on your explicit opt-in consent;
· Legal Compliance: Data retention and processing to meet national supervision, tax inspection, and tourism industry regulatory requirements.
For direct marketing activities, we will obtain your separate consent in jurisdictions requiring authorization. You have the right to object to marketing data processing at any time without providing reasons.
Ⅳ. Disclosure of Personal Data to Third Parties
We will never sell your personal data for commercial profit. We only share your data with third parties in the following legitimate scenarios, and all cooperative third parties have signed strict confidentiality agreements:
· Travel Service Suppliers: Share necessary information with scenic spot operators, ticket service providers, vehicle transfer suppliers, hotel accommodation providers, catering merchants, and tour guide teams to complete travel service arrangement;
· Group Internal Sharing: Authorized data sharing within China Merchants International Travel Agency Group subsidiaries and affiliated institutions for unified service management and user experience optimization;
· Technical & Operation Service Providers: Provide data to cloud service providers, website operation and maintenance teams, data security institutions, and customer service systems for platform normal operation;
· Legal & Supervision Requirements: Disclose data in response to official legal inquiries, judicial procedures, and regulatory supervision requirements;
· Risk Prevention & Emergency Response: Disclose necessary information to prevent fraud, illegal acts, and personal safety risks, or contact emergency contacts in case of travel emergencies;
· Business Restructuring: In the event of group merger, asset transfer, or business reorganization, transfer user data to the successor entity under legal supervision.
We may share anonymous and aggregated non-identifiable user data for industry analysis, service optimization and market research.
Ⅴ. Cross-Border Data Transfer
As an international travel service provider, we may transfer your personal data to overseas service providers, social media platforms, and technical service institutions for service delivery and platform operation.
We strictly abide by GDPR, UK data protection laws, CCPA, and other global privacy regulations. All cross-border data transfers are supported by standardized legal mechanisms including Standard Contractual Clauses (SCCs) and Binding Corporate Rules. We will conduct strict qualification review and data security assessment for all overseas third-party partners to ensure your personal data obtains equivalent protection overseas.
Ⅵ. Data Security & Data Retention
1. Security Protection Measures
We adopt complete technical and organizational security measures to protect your personal data from unauthorized access, disclosure, tampering, loss, and illegal processing, including data encryption, access permission management, regular system security detection, and employee confidentiality training.
All third-party data processors are required to sign confidentiality agreements and abide by unified data security management specifications.
2. Data Retention Rules
We only retain your personal data within the period necessary to achieve the processing purpose:
· Service data: Retained during the service cycle and deleted after the completion of after-sales follow-up;
· Financial and transaction data: Retained for at least 7 years in compliance with tax and financial supervision requirements;
· Legal dispute data: Retained until the completion of dispute settlement and legal proceedings;
· Anonymous data: May be retained indefinitely for data analysis and service optimization.
Ⅶ. Your Legal Privacy Rights
You have the right to exercise the following personal data rights by contacting our official privacy email:
· Right of Access: Request inquiries and obtain copies of your personal data stored by us;
· Right of Rectification: Request correction and improvement of inaccurate or incomplete personal data;
· Right of Erasure: Request deletion of your personal data when the processing purpose is fulfilled or the processing is illegal;
· Right of Restriction of Processing: Request suspension of partial data processing when data accuracy is disputed or processing is suspected to be illegal;
· Right of Objection: Object to legitimate interest processing and direct marketing data processing at any time;
· Right of Data Portability: Request data export and transmission under applicable legal conditions;
· Right of Consent Withdrawal: Withdraw previously authorized data processing consent at any time;
· Right of Complaint: File complaints with local data protection supervision authorities if you believe our data processing violates relevant laws.
We will respond to all legitimate user requests within one month, with a maximum extension of two months for complex requests, and will actively inform you of the progress and reasons.
Ⅷ. Special Notice for U.S. Residents (CCPA/TDPSA Compliance)
Residents of California, Texas, and other U.S. states with data privacy legislation enjoy additional statutory rights, including the right to know, right to correct, right to delete, and right to opt out of targeted advertising data sharing.
We do not sell your personal data for monetary consideration. Part of data sharing with advertising and analysis partners may be defined as “sharing” under U.S. state laws. U.S. users may exercise opt-out rights through our official contact channels.
We do not recognize unauthorized DNT signals but comply with Global Privacy Control (GPC) opt-out mechanisms. We will not discriminate against any user who exercises privacy rights.
Ⅸ. Social Media & Third-Party Website Disclaimer
Our official website contains links to third-party social media platforms and external websites. We are not responsible for the privacy policies, data processing rules, and content security of third-party platforms.
All interactive behaviours and personal information submitted on third-party social media platforms are subject to the protection rules of the corresponding platforms. We recommend that you carefully check the privacy settings of third-party platforms before interaction.
Ⅹ. Pixel Notice
1. Definition and Purpose of Pixels
Our website uses pixel tags (also known as web beacons, clear GIFs, or tracking pixels), embedded scripts, and log analysis technologies to recognize visitors, track browsing behaviour, measure advertising effectiveness, optimize service experience, and analyse website operation data.
2. Types of Pixels We Use
· Strictly Necessary Pixels: Essential for website security, normal access, and basic service functions.
· Functional Pixels: Used to remember user preferences, language settings, and browsing behaviour to improve usability.
· Analytics & Advertising Pixels: Used to collect anonymous data for traffic analysis, advertisement delivery, conversion tracking, and service optimization.
3. Pixel Management
You can manage or disable pixel tracking through your browser settings, privacy tools, or advertising opt-out platforms. Disabling some pixels may affect personalized functions but will not prevent basic website access. We do not sell or disclose pixel-collected personal data to unauthorized third parties.
Ⅺ. Update of This Notice
We have the right to update this Privacy & Pixel Notice according to business adjustment and legal requirement changes. The updated version will be published on the official website with the latest effective date. Continued use of our website and services after the update is deemed as acceptance of the revised terms.
Ⅻ. Contact Us
If you have any questions, suggestions, or rights exercise requirements regarding personal data processing, please contact our official privacy team via our dedicated email address.
Official Privacy Contact Email: zhangfengyue850@gmail.com