Privacy Policy

1. Who We Are

China Holiday Gems is a Shanghai-based private travel and destination management brand operated by:

Legal company name: Shanghai Yilian International Travel Service Co., Ltd.
Registered address: Room 721, No. 800 Shangcheng Road, China (Shanghai) Pilot Free Trade Zone, Shanghai, P.R. China
Trading name: China Holiday Gems
Privacy contact: [email protected]

For applicable privacy laws, we act as the organisation responsible for deciding how and why your personal information is processed. Depending on the relevant law, this may be described as the data controller or personal information processor.

2. When This Policy Applies

This Policy applies when you:

• visit chinaholidaygems.com;
• submit a private travel enquiry;
• submit a MICE or corporate event brief;
• communicate with us by email, telephone or WhatsApp;
• request a proposal, quotation or travel arrangement;
• interact with us in connection with a current or potential booking.

Third-party websites and services linked from our website have their own privacy policies. This Policy does not control their independent activities.

3. Personal Information We Collect

Information you provide

Depending on how you interact with us, we may collect:

• your name, email address, telephone number or WhatsApp number;
• your country of residence;
• your company or organisation and work email address;
• preferred travel dates, trip duration and destinations;
• number of adults and children travelling;
• travel interests, preferred pace and accommodation style;
• indicative budget information;
• event type, estimated delegate numbers, preferred cities and requested MICE services;
• information contained in your travel or event brief;
• correspondence, feedback and records of our communications.

You may also choose to provide dietary, accessibility, mobility or other practical information. Some of this may be considered sensitive personal information under applicable law. Please provide only what is reasonably necessary for us to understand and respond to your request.

Please do not submit passport details, payment-card information or other official identification through our initial website enquiry forms.

Information collected automatically

When you use the website, our hosting, security and delivery providers may automatically process limited technical information, such as:

• IP address;
• browser and device type;
• operating system;
• pages requested and approximate request time;
• referring page;
• security, diagnostic and server-log information.

We use this information to deliver the website, maintain security, diagnose errors and prevent misuse.

Information received from other sources

We may receive information from you through email, WhatsApp or another service you choose to use. We may also receive information from travel suppliers, event partners or a person arranging travel on your behalf where this is necessary to manage an enquiry or booking.

4. How We Use Personal Information

We may use personal information to:

• respond to your questions and enquiries;
• understand your interests, preferences and practical requirements;
• design private itineraries, MICE programmes and event proposals;
• prepare quotations and discuss potential bookings;
• communicate with you about an enquiry, proposal or confirmed service;
• arrange travel services with hotels, guides, transport providers, venues and other suppliers;
• provide assistance before, during and after a journey or event;
• manage our business records and meet legal, accounting or regulatory obligations;
• protect our website, systems, customers and business from fraud, spam and security threats;
• improve our services using aggregated or appropriately de-identified information;
• send marketing communications only where we have the required permission or another lawful basis to do so.

We do not use personal information submitted through an enquiry form for unrelated advertising purposes.

5. Legal Bases for Processing

The legal basis we rely on depends on the information, purpose and law that applies. It may include:

• Steps at your request or performance of a contract: to respond to an enquiry, prepare a proposal or provide booked services.
• Legitimate interests: to operate our business, provide customer service, maintain website security and improve our services, where those interests are not overridden by your rights.
• Consent: where you have made a clear choice, including for optional marketing or certain sensitive information.
• Legal obligations: where information must be processed or retained to comply with applicable law.
• Vital interests: in exceptional circumstances where information is necessary to protect someone’s health or safety.

Where sensitive or special-category information is provided, we will process it only when necessary and when an appropriate legal condition—such as explicit consent—applies.

You may withdraw consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

6. Cookies and Similar Technologies

Our website may use strictly necessary cookies or similar technologies required for website delivery, security, network management and fraud prevention.

At the date of this Policy, we do not intentionally use advertising cookies or behavioural tracking pixels on the website. If we introduce optional analytics, advertising or personalisation technologies, we will update this Policy and provide an appropriate consent or preference mechanism where required.

You may also manage cookies using your browser settings. Blocking strictly necessary technologies may affect website availability or security.

When you click an external WhatsApp, Instagram, TikTok, YouTube or Threads link, the relevant provider may collect information under its own privacy policy. These services are not activated merely by displaying a standard outbound link on our website.

7. How We Share Information

We do not sell personal information. We do not share personal information for cross-context behavioural advertising.

We may share information only when reasonably necessary with:

• website hosting, infrastructure, security and email providers;
• professional advisers, such as legal, accounting or insurance advisers;
• hotels, guides, transport providers, venues, restaurants and other travel or event suppliers;
• technology and communications providers used to manage enquiries and bookings;
• government bodies, regulators, courts or law-enforcement authorities where legally required;
• a purchaser or successor if our business is reorganised, merged or transferred, subject to appropriate confidentiality protections.

Travel and event suppliers receive only the information reasonably needed to quote, arrange or provide the requested service. Some suppliers act on our instructions, while others process information independently under their own privacy policies.

8. International Data Transfers

China Holiday Gems is based in China and serves travellers and organisations from different countries. Your information may therefore be processed in China and in other countries where our service providers or travel partners operate.

Privacy laws and protections may differ between countries. Where applicable law requires safeguards, notices, consent or contractual protections for an international transfer, we will take reasonable steps to meet those requirements.

You may contact us if you would like more information about how your information is handled in connection with an international transfer.

9. How Long We Keep Information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected.

Unless a longer period is required for an active relationship, dispute or legal obligation:

• enquiry-only information is ordinarily retained for up to 24 months after our last meaningful communication;
• booking, transaction and supplier records may be retained for longer where required for contractual, tax, accounting, insurance or legal purposes;
• security and server logs are normally retained for a shorter operational period;
• information processed solely on the basis of consent will be reviewed when consent is withdrawn.

We may retain anonymised information that no longer identifies an individual.

10. How We Protect Information

We use reasonable administrative, organisational and technical measures designed to protect personal information from unauthorised access, loss, alteration, misuse or disclosure.

Access is limited to people and providers who reasonably need the information for their work. However, no website, email system or method of electronic transmission can be guaranteed to be completely secure.

If you believe information you provided to us may be at risk, please contact us promptly.

11. Your Privacy Rights

Depending on your location and the applicable law, you may have the right to:

• receive information about how your personal information is used;
• request access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• request deletion of personal information;
• request restriction of certain processing;
• object to processing based on legitimate interests or direct marketing;
• receive certain information in a portable format;
• withdraw consent;
• complain to an applicable data-protection authority;
• request information about recipients or international transfers.

These rights may be subject to legal conditions and exceptions.

To make a request, email [email protected] with the subject line Privacy Request. We may need to verify your identity before responding. We will use information supplied for verification only to process and protect your request.

You will not be discriminated against for exercising an applicable privacy right.

12. Additional Information for California Residents

Where the California Consumer Privacy Act and its amendments apply to us, California residents may have rights to:

• know the categories and specific pieces of personal information collected;
• know the sources, purposes and categories of recipients;
• request correction or deletion;
• opt out of the sale or sharing of personal information;
• limit certain uses of sensitive personal information;
• receive equal service and pricing when exercising privacy rights.

China Holiday Gems does not sell personal information and does not share it for cross-context behavioural advertising.

Requests may be submitted to [email protected]. An authorised agent may submit a request where permitted by law, although we may require evidence of the agent’s authority and appropriate identity verification.

13. Children’s Information

Our website and enquiry services are intended for adults arranging travel or events.

We do not knowingly ask children to submit enquiries directly. An adult traveller, parent or guardian may provide limited information about the number of children travelling and their relevant travel needs.

Please do not provide a child’s passport details, identification numbers or unnecessary personal information through the initial enquiry form.

If you believe a child has submitted personal information without appropriate involvement from a parent or guardian, please contact us.

14. Third-Party Links and Social Media

Our website contains links to services such as WhatsApp, Instagram, TikTok, YouTube and Threads. Clicking one of these links takes you to a third-party service.

Those providers determine how they collect and use information on their platforms. We encourage you to review their privacy policies before providing information.

15. Changes to This Policy

We may update this Privacy Policy when our services, technology or legal obligations change.

The latest version will be published on this page with a revised “Last updated” date. Material changes may also be communicated through the website or another appropriate channel.

16. Contact Us

For privacy questions or requests, contact: