Where Confidence Begins

I. Introduction

SinoVistas (“SinoVistas,” “us,” “our,” or “we”), a specialized Chinese travel agency dedicated to creating unforgettable travel experiences in China for overseas Chinese and English-speaking travelers, recognizes the importance of protecting your privacy.

This global privacy notice (“Notice”) describes how we collect, process, and share the personal data of our guests (“Guest Personal Data”). It also describes your rights and choices regarding your data. This Notice applies to our website and all services offered by SinoVistas.

For the purposes of applicable data protection laws, SinoVistas acts as the “data controller” of your Guest Personal Data. We have appointed a Data Protection Officer to oversee all privacy-related matters.

This Notice is written in English. To the extent any translated version of this Notice conflicts with the English version, the English version shall control.

II. How We Collect Your Data

We collect your data in three main ways:

• Information You Provide to Us: We collect the personal data you choose to give us when you book a trip, contact our team, speak with our representatives, or purchase our services.

• Information Collected Automatically: When you visit our website, we automatically collect certain technical information through cookies and similar technologies, such as your IP address, device information, and browsing activity.

• Information We Obtain Indirectly: We may receive your data from trusted partners, such as a travel agent who books a trip on your behalf, or from marketing and social media platforms (like Facebook or WeChat) when you interact with our services through them.

III. Minors’ Privacy

Our services are not intended for use by individuals under the age of 18 (“Minors”) without the consent of a parent or guardian. We do not knowingly collect personal information from Minors. If you believe we may have collected information from a Minor, please contact us at privacy@sinovistas.com so we may delete it immediately.

IV. What Data We Collect & For What Purpose

We only collect the data that is essential to plan and deliver your trip to China. The table below outlines the types of Guest Personal Data we collect and the primary reasons we need it.

V. Legal Grounds for Processing Your Data

We process your data legally and fairly, based on the following grounds:

• Performance of a Contract: Most importantly, we process your data to fulfill the contract we have with you—that is, to book and deliver the trip you have purchased.

• Consent: For certain activities, such as sending marketing emails or processing sensitive health data, we rely on your explicit consent.

• Legitimate Interest: We may process your data for our legitimate business interests, such as improving our services or preventing fraud, but only when our interests do not override your rights.

• Legal Obligation: We will process your data where we have a legal requirement to do so, such as complying with requests from law enforcement or immigration authorities.

VI. Important Note on Special Category (Sensitive) Data

To ensure your safety and provide the high-quality service you expect, we may need to collect sensitive information, such as details about your health or dietary needs.

Providing this information is voluntary. However, by providing it, you give us your explicit consent to use this data and share it with our suppliers (like hotels or tour guides) for the sole purpose of arranging your trip and ensuring your well-being.

If you are not comfortable with this, we may not be able to confirm that a trip is suitable or safe for you. If you choose to withdraw your consent after booking, preventing us from making necessary arrangements, we will have to treat this as a cancellation of your booking, and the cancellation charges outlined in our Booking Terms and Conditions will apply.

VII. Disclosures of Your Data to Third Parties

We want to be clear: we do not sell your personal data. We only share it in the following necessary circumstances:

• Travel Service Suppliers: We share your data with our trusted partners in China—including hotels, airlines, local guides, and transport providers—to arrange and confirm the components of your trip.

• Essential Service Providers: We may share data with third-party companies that provide essential services on our behalf, such as IT hosting, secure payment processing, and marketing communications.

• Legal and Emergency Situations: We may disclose your data to comply with a legal request or to protect the vital interests and safety of any person in an emergency.

VIII. International Data Transfers

As an international travel agency, transferring your data across borders is essential to providing our services.

• Transfers to China: To book your trip, your Guest Personal Data will be transferred to our partners and suppliers located within China.

• Global Service Providers: Our technical service providers for things like data hosting or analytics may be located in other countries, such as the United States.

When we transfer your data out of jurisdictions with specific data transfer laws (such as the UK or the European Economic Area), we use legally-approved safeguards, like Standard Contractual Clauses, to ensure your data receives an adequate level of protection.

IX. Data Security and Retention

We are committed to keeping your personal information secure. We maintain appropriate technical and organizational security measures to protect your data against loss, misuse, and unauthorized access. While we take all reasonable steps to protect your data, please be aware that no system is 100% secure.

We will only keep your Guest Personal Data for as long as is necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. For example, by law, we may need to keep basic information about our guests for up to seven years for tax purposes.

After this period, we may de-identify or anonymize your data for research or statistical purposes, and we may use this information indefinitely without further notice to you.

X. Your Privacy Rights

You have fundamental rights and control over your personal data. You can make a request to exercise any of these rights at any time by contacting our Data Protection Officer.

Responding to Your Requests: We will respond to your requests within one month. We will not charge a fee unless your request is clearly unfounded or excessive. For your security, we may need to verify your identity before proceeding with a request.

XI. Special Notice for U.S. Residents

If you reside in a U.S. state with specific privacy laws (such as California), you have rights which may include the right to opt out of the “sale” or “sharing” of your personal information for targeted advertising. While we do not sell your data for money, our use of online advertising partners may be considered a “sale” or “share” under these laws. You can exercise your right to opt out by contacting us.

XII. Cookies & Other Technologies

Our website uses standard technologies like cookies, web beacons, and server logs to collect information about how our website is used, to improve your experience, and for advertising purposes. For more detailed information, please see our separate Cookie Policy.

XIII. Changes to this Notice

We may update this Privacy Notice from time to time. If we make any material changes, we will post the revised notice on this page and update the “Last Updated” date.

XIV. Questions & Contact Us

If you have any questions, concerns, or wish to exercise your rights, please contact our Data Protection Officer.

• Email: privacy@sinovistas.com