Data Controller: Guangdong Train of Glamour Tourism Co., Ltd.
Travel Agency Business License No.: L-GD-102774
Contact Email: support@silkroadluxurytrains.com
The Train of Glamour respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.
A.Purpose of this Privacy Notice
1.This privacy notice aims to give you information on how Train of Glamour collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc.
2.This Policy is intended to address the compliance requirements set forth under the Personal Information Protection Law of the People's Republic of China (PIPL) and the EU General Data Protection Regulation (GDPR). Users in different jurisdictions may exercise the corresponding rights described herein to the extent provided under the laws applicable to them.
3.This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party. The information of minors shall be provided by their guardians, and the guardians shall assume liability for the accuracy and lawfulness of the information so provided.
4.It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
5.It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
B.Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
C.The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
1.Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, or similar identifier, marital status, title, date of birth, gender and ID Document Number (ID Card/Passport).
2.Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
3.Financial Data
This includes data relating to your means and methods of payment. We do not retain the full bank card or credit card numbers. The complete payment card data is held and processed by third-party payment service providers.
4.Transaction Data
This includes information pertaining to your transactions with us, including, but not limited to, payment details, order numbers, refund records, and other details concerning the products and services you have acquired from us.
5.Technical Data
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
6.Usage Data
This includes information about how you use our website, products and services.
7.Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
D.Special Categories of Personal Data
1.We collect the following special categories of personal data about you.
- dietary requirements which may disclose your religious or philosophical beliefs;
- health information and medication allergy details;
We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
2.You are not under any obligation to consent to us processing your sensitive personal data. To the extent that such information is necessary for the provision of travel services (for example, dietary allergies for onboard meal arrangements), we will be unable to make the required arrangements or provide the travel services you have booked or attempted to book without your consent. For non-essential health information, your withdrawal of consent will not directly result in the cancellation of your booking.
3.If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. If the consent withdrawn relates to sensitive information that is essential for the delivery of the travel services, we will not be able to fulfill the travel services you have reserved. Under such circumstances, the withdrawal of consent will be treated as a request for cancellation on your part and shall be governed by the Refund and Cancellation Policy.
E.If you fail to provide personal data
1.Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
2.In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book.
3.In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a “cancellation by you” in accordance with our Booking Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.
F.How your personal data is collected
We use different methods to collect data from and about you including through:
1.Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you :
- make a booking of travel services;
- subscribe to our newsletter or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us some feedback;
- provide your consent to use of your images for marketing purposes.
2.Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
G.How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1.Where we need to perform the contract we are about to enter into or have entered into with you.
2.Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (Applicable only to users in the EU/EEA under the GDPR).
3.Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or telephone. You have the right to withdraw consent to marketing at any time via Contact Us.
H.Purposes for which we will use your personal data
1.We have provided a deion of the ways in which we intend to use your personal data, together with the legal bases upon which we rely for such processing. Where applicable, we have also set out our legitimate interests.
2.Please be aware that, depending on the specific purpose for which your data is used, we may process your personal data on more than one legal ground. Should you require further information concerning the specific legal basis applicable to the processing of your personal data, please contact us, as multiple legal bases may be relevant.
I.Categories of Third-Party Data Recipients
1.To perform the travel contract, we share only the minimum necessary personal information with the following partners. All partners have entered into confidentiality agreements and are permitted to use such information solely for performance of the contract, and are prohibited from using it for any other purpose: railway operators, ground reception service providers, hotels, insurance institutions, and third-party payment service providers.
2.We Never Sell Personal Information: Whether under the GDPR or China's PIPL, we do not sell, trade, or transfer your personal information for monetary or other valuable consideration. The limited sharing of necessary data with the above service providers for contract performance does not constitute a“sale”of personal information as defined by applicable law. We will not transfer your personal information without your explicit written consent, nor will we proactively disclose your personal information except as required by law or by judicial order.
J.Cross-Border Transfer of Personal Information
When you choose cross-border travel routes, or when you are located outside China (e.g., in the EU), cross-border transfers of personal information may occur:
1.Where such transfer constitutes a cross-border data transfer under Chinese law, we will comply with the PIPL, complete such transfer through lawful compliance pathways, and obtain your separate consent for cross-border processing.
2.For users in the EU/EEA under the GDPR, such transfers will be subject to appropriate safeguards (including Standard Contractual Clauses (SCCs)) to ensure data security.
Only the minimum information necessary for the provision of travel services will be transferred; no bulk or irrelevant cross-border data exports will be made.
K.Data Retention Period and Security Measures
1.Retention Period: Personal information associated with an order will be retained for five (5) years from the end of the itinerary, for purposes of contract performance, dispute resolution, and regulatory compliance archiving. Website access logs will be retained for twelve (12) months. Upon expiry, such data will be anonymized or securely destroyed. Where laws require longer retention periods, such legal requirements shall prevail.
2.Security Measures: We implement technical and organizational measures including encrypted storage, permission isolation, internal confidentiality policies, and access audits to protect your information and mitigate the risks of disclosure, tampering, or loss. Please note that transmission over the internet cannot be guaranteed to be 100% secure.
3.In the event of a personal information security incident, we will notify affected users and regulatory authorities in a timely manner as required by applicable law.
L.Your Rights as a Data Subject
To the extent permitted under applicable law in your jurisdiction, you may exercise the following rights. To exercise your rights, please email us at support@silkroadluxurytrains.com, stating your booking reference number and cooperating with identity verification.
1.Right to Know / Right of Access: You have the right to know what categories of your personal information we process and to obtain a copy of the personal information we hold about you (consistent with the PIPL and GDPR).
2.Right to Rectification: If you find errors in your name, contact details, identification documents, etc., you may request correction.
3.Right to Erasure (Right to be Forgotten): Under certain statutory conditions, you may request deletion of your personal information. However, we may retain information required by law to be retained (including but not limited to order records, financial records, and compliance archives) in accordance with applicable law (consistent with the PIPL and GDPR).
4.Right to Withdraw Consent: You may withdraw your consent to the processing of your personal information at any time. Such withdrawal does not affect the lawfulness of processing based on consent prior to withdrawal. If the consent withdrawn pertains to information necessary for the performance of the travel services, we will no longer be able to provide the travel booking services.
5.Right to Data Portability (GDPR): Users in the EU/EEA have the right to obtain their personal data relating to orders in a structured, commonly used, and machine-readable format.
6.Right to Restriction of Processing and Right to Object (GDPR):Under certain statutory conditions, you may request restriction of or object to the processing of your personal information.
7.Response Timeframes: For users in mainland China, we will respond within fifteen (15) business days after verifying the request; for GDPR governed users, within one (1) month.
8.If you believe your personal information rights have been infringed, you also have the right to lodge a complaint with the competent local data protection authority.
M.Cookies and Similar Tracking Technologies
Our website uses cookies to remember browsing preferences and ensure normal website access. You may refuse or clear cookies through your browser settings. If you refuse cookies, certain features of the website may not function properly. We do not sell user data collected through cookies to third parties.
N.Adjustments to This Privacy Policy
We reserve the right to adjust this Privacy Policy. The adjusted version will be posted on the Privacy Policy page on our official website. Material changes will be highlighted prominently. Orders already confirmed are subject to the version of the Privacy Policy in effect at the time the booking was made.
O.Contact Us
If you have any questions, requests, or complaints regarding this Privacy Policy or our processing of your personal information, please contact us.
1.Data Controller: Guangdong Train of Glamour Tourism Co., Ltd.
2.Travel Agency Business License No.: L-GD-102774
Contact Email: support@silkroadluxurytrains.com