Privacy Policy

1. Who we are and other important information

We are Tang Dynasty Tours Co., Ltd., which owns Odynovo that provides custom travel services in popular destinations across the world. We take your privacy seriously and are committed to protecting your personal information.

This privacy policy (as well as other documents including our Cookie Policy and Social Media Policy that are mentioned in this privacy policy) applies to this website (https://www.odynovotours.com), and aims to inform you why we collect, how we collect, use, disclose, and store any personal information about our customers, potential customers, people who visit our website, and anyone else whose information may be processed by us during our business operation. We encourage you to read this privacy statement carefully so that you can have a clear understanding of how we handle your personal data.

2. What information we may collect about you

We collect your personal information only out of necessity or with your consent. The information we collect about you consists of the information you give us, automatically collected information, and information provided by third parties. This includes:

2.1 Information you give us

During your communication or interaction with us, you may offer us different personal information at different times.

2.1.1 When you send us a tour inquiry or request a quote

Generally, your name, email address, hotel class, number of people, estimated travel date, phone number, and WhatsApp account. Besides, you may also offer us other optional personal information, such as your age, gender, nationality, phone number, destinations you wish to visit, preferred hotels and airlines, special requirements such as a request for a wheelchair, food preferences, and information relating to your travel companions if you wish to.

2.1.2 When you communicate with our travel consultant to customize your tour via email, phone or other means such as WhatsApp and Skype

Generally your phone number and email address. Yet to better understand your requirements hence offer better services to you, we may also ask you to provide your social media information relating to Facebook, WhatsApp, Skype and other instant messaging applications, address, emergency contacts, health conditions, disabilities, and dietary restrictions.

2.1.3 When you book our travel services

Generally your full name, gender, nationality, birthday, passport information such as passport number and passport expiration date, and if necessary, visa information, preferred hotel room (e.g. whether or not you prefer a high floor room, or non-smoking room), and seat preference on an airplane or a train, and food allergies.

2.1.4 When you make a payment for our services

Depending on your payment methods, the information you give us may vary. For example, if you pay via wire transfer, you need to provide us with the photo/scanning copy of the bank slip or similar document so that we can confirm the payment has been made to the correct bank account. In this case, we will be able to see your basic bank account information including bank name, account name, account number etc.

If you pay by credit card authorization, you will need to offer us your passport information, credit card information and possibly your billing address.

If you use online payment such as PayPal, we do not collect personal information as you will pay through the widgets of PayPal or other online payment service providers, in this case, you only need to open the payment link that we send you and follow the steps to finish the payment. However, we will be able to see your name from the transaction record which helps us confirm who has paid to us.

2.1.5 When you sign up for our newsletters

Your name and email address.

2.1.6 When you are happy with our services and refer other people to book our services

Name, email address of both you and the people you refer, and customer ID, so that we can know who is recommended to us and entitled to enjoy our referral benefit.

2.1.7 When you take part in our giveaways, promotions or campaigns

Usually your name, email address, destination interested, travel date, and possibly other special requirements regarding flight, food, accommodation, etc. which may vary slightly from case to case.

2.1.8 Other information you may give us

1) Photos and videos taken or made by you or your tour guide, your travel companion, or other people featuring you and a destination. We will get explicit consent and authorization from you and your travel companion (if he/she appears in the photo or video) before we use them. However, we will have to rely on you or one of the group members to collect all the consent on our behalf as we may not be able to ask each of the group members for their consent personally. The photos and videos may be shown on our website and possibly other channels to help us provide travel inspirations and ideas to our customers and potential customers.

2) Feedback and reviews on our service written by hand or made via email, phone, instant messaging software etc.

Note:

We take children's privacy seriously. We will not deliberately collect, use and share the personal information of children under the age of 18. If you book travel services from us on behalf of any child, we will collect his or her information from you to perform such services and we will work hard to keep this information safe.

This privacy policy is also applicable to your travel companions on whose behalf you book our services. We have to assume that you have a right to share their personal information with us as we may not always have the chance to communicate with them personally. So if you book our services on their behalf, we rely on you to explain this privacy notice to them and gain their explicit consent before you share their information with us.

2.2 Automatically collected information

Your personal data may be automatically collected when you access our site, or contact us via Livechat, email, phone, or inquiry forms:

2.2.1 Technical data when you visit our website, including the internet domain, IP address or other device feature (such as screen resolution and type of device, e.g. tablet or PC), operating system, browser type/version, referral website, and how you navigate through our website (such as visit duration, pages viewed etc.). These data are shown to us as aggregated data and allow us to understand our visitors in a holistic way rather than in an individual way. We use this information to optimize our website/services, so that all the visitors including you can have a better experience with us. These types of data are mostly collected by cookies set by us or third parties (Facebook Pixel, Livechat etc.). We also use other tracking technologies similar in function to Google Analytics to collect data about the usage of our website, in order to understand and boost website performance. If you wish to know more details about cookies, please see our Cookie Policy.

2.2.2 Caller information (e.g. your phone number) when you give us a phone call, email address when you contact us by email, or similar contact information when you contact us in other methods.

2.3 Information provided by third parties

2.3.1 Personal information mentioned in section 2.1 of this privacy policy that is given by your family members and travel companions who book a tour from us on your behalf.

2.3.2 Information provided by analytics tools. For instance, Google Analytics, Facebook Pixel and Livechat provide us statistical data about our visitors, for example, average visit duration, percentage of users who view a specific page, exit rate, bounce rate etc. These are aggregated data to help us better understand visitors' behavior as a whole and improve our website accordingly.

If you have opted-in for our newsletters, Emarsys as our email marketing service supplier let us know how you interact with our newsletter content, such as the open rate, click rate of a specific link, whether or not you have unsubscribed our newsletters etc.

2.3.3 Information provided by our partners such as cruise lines, airlines, hotels who have run marketing campaigns for our products/services and online travel agencies (for example Expedia) through which you book our travel services. Personal information including name, nationality, passport information, email address, travel date, flight information, pickup location etc.（depending on different partners or agencies, some or all of the above-mentioned data）will be provided to allow us to handle your booking.

2.3.4 The Information mentioned in 2.1.1, 2.1.2, and 2.1.3 provided by a travel agent through which you book our travel services.

2.3.5 Feedback, reviews, and comments on our products / services you leave on review platforms including TripAdvisor, Trustpilot, ProductReview.com.au, and Feefo etc.

2.3.6 Social media information, which is collected when you interact with us on Facebook, Twitter, Instagram, Pinterest, YouTube, etc. This information may include basic account information (name, nationality, etc.), and contents you share (such as comments, messages, reviews, photos, and videos).

If you wish to communicate with us via email, phone or instant messaging applications such as WhatsApp and WeChat, you may offer us your contact information including your email address, and phone number via social media. For details about how we use and protect this information, please refer to our Social Media Policy.

3. How we use your information and lawful basis for using

We will never sell your information we hold about you to any third party, and will only use it out of necessity or based on your consent and in accordance with applicable laws and regulations, as set out in this Privacy Policy. Most commonly, we will use your information relying on the following lawful basis:

• Necessity for entering into contracts with you: in order to enter into contracts with you, we will need to use certain information to provide you with the information you inquire about.
• Necessity for performing contracts with you: in order to perform our contracts with you, we will need to use certain information to provide you with products and service you book with us.
• Your consent: we will send you our newsletters, which may contain our destination information, offers, and promotions etc., based on your consent. You may withdraw such consent at any time.
• Necessity for our legitimate interests and those of third parties: we use your information relying on reasonable legitimate interests, e.g. for delivering best possible customer experiences, improving our products/services, promoting our business etc. More legitimate interests will be set out in below.
• Necessity for complying with legal and regulatory obligations applicable to us: For example, we will record your choice of opting-out our newsletter, so that we are able to ensure that we respect your such right by stop delivering any further newsletter to you.
• Necessity for protecting your vital interests when you are unable to give us consent: we may use or share your information to safeguard your vital interests when you are unable to give us consent, for instance, we may share your information to a medical services provider in an emergency.

We will use your information we hold about you for the following specific purposes:

3.1 Inquiries

We use your information to:

3.1.1 Provide you with the information you have inquired about and those we believe is related to your inquiry or may interest you.

3.1.2 Customize itineraries for you (and your travel companions) according to your requirements, group size, physical conditions, interests etc.

3.1.3 Communicate with you regarding your inquiries and requests.

We rely on the following lawful basis:

• Necessity for entering into contracts with you;
• Necessity for our legitimate interests in communicating with you after you interact with us e.g. sending an inquiry to us; and dealing with your inquiries and requests effectively and efficiently.

3.2 Bookings

We use your information to:

3.2 1 Manage your booking, including completing your requirements;

3.2.2 Make bookings and reservations (of accommodation, flights, etc.) on your behalf and on behalf of your travel companions if any;

3.2.3 Communicate with you regarding the booking, including sending you booking confirmation letters and other travel related documentation;

3.2.4 Communicate and cooperate with our travel business partners, e.g. our local ground operators, to make sure that you and your travel companions receive the products and services you book with us;

3.2.5 Provide you with customer support and customer services to ensure your trip is going smoothly;

3.2.6 Verify your booking and payment, and collect and recover money receivable.

We rely on the following lawful basis:

• Necessity for performing contracts with you;
• Necessity for our legitimate interests in providing our products and services effectively and efficiently; enabling and assisting our travel business partners involved to comply with their legal and regulatory obligations; using your information to follow up with you; and protecting our business against financial loss.

3.3 Website and systems

We use your information to:

3.3.1 Optimize your browsing experience on our website. For example, by presenting suitable website layout according to the screen size of your device (e.g. mobile phone or PC) and so on.

3.3.2 Improve your user experience with us. For example, by removing rarely-filled-out items on the inquiry form to simplify the steps you need to take to request a quote and so on.

3.3.3 Maintain and improve the integrity and the security of our website, systems and data (such as troubleshooting and system maintenance);

3.3.4 Improve the content and products on our website.

We rely on the following lawful basis:

• Necessity for our legitimate interests in operating our website efficiently and effectively; maintaining and improving the integrity and security of our website, systems and data we hold; and improving customer experience on our website.

3.4 Marketing and promoting

We use your information to:

3.4.1 Send you our informative newsletters based on your consent;

3.4.2 Contact you for market research;

3.4.3 Invite you to enter into a prize draw, giveaway, promotion or campaign

3.4.4 Market and/or promote our products and services outside our website, e.g. on Google, YouTube.

3.4.5 Measure the effectiveness of our marketing and promotional efforts；

3.4.6 Inform you of some important company/travel news and discount/deals information that is related to your inquiry or may interest you.

We rely on the following lawful basis:

• Necessity for our legitimate interests in promoting our business, products and services; and ensuring our marketing and promoting is relevant to your preferences and/or interests.
• Our sending of newsletters to you is based on your consent. You may withdraw your consent at any time.

3.5 Business improvement

We use your information to:

3.5.1 Conduct research/analysis to optimize our products and services and find best possible products and services for you and other customers;

3.5.2 Invite you to participate in a survey, and/or leave a review on our products and services, which might be used on our website and other marketing channels such as our newsletters.

3.5.3 Manage our relationship with you, such as sending you birthday greetings, etc.

3.5.4 Maintain our records and audit our business;

3.5.5 Train our staff, including travel specialists, so that they are able to offer better service to you and other customers;

We rely on the following lawful basis:

• Necessity for our legitimate interests in improving our business, products and services; and operating and managing our business in an organized and efficient way.

Note: Some review platforms (e.g. Trustpilot and Feefo) run an invite-only process for posting verified comment, hence customer name and email address are needed before sending customer a review invitation email. We may share such information with these platforms in order for you to leave a review. When you agree to let us display your review (which may include the time of the review, star rating, review title, review content and your name), we may use your review on our website and other marketing channels.

3.6 Legal purposes

We use your information to:

3.6.1 Keep factual information for resolving possible disputes, legal proceedings, etc.;

3.6.2 Communicate with you and deal with your requests regarding your rights to your personal information as set out in this Privacy Policy;

3.6.3 Share certain information about you to regulators and competent authorities as required and requested by them;

3.6.4 Help detect and prevent fraud and other criminal activities.

We rely on the following lawful basis:

• Necessity for our legitimate interests in making sure we can demonstrate that we comply with laws and regulations applicable to us; and cooperating with competent authorities, including in tax auditing, crime detection and prevention, etc.
• Necessity for complying with legal and regulatory obligations.

3.7 Emergency

We use your information to:

3.7.1 Assist you or arrange third parties, such as medical service providers, to provide assistance to you in the event of an incident or emergency, when you are unable to give us consent.

We rely on the following lawful basis:

• Necessity for protecting your vital interests.

3.8 Social Media

We may use your social media information that we collect when you engage with us on social media (such as Facebook and YouTube) in several ways, including to respond to you, provide you with the information you requested, etc. For more information about what kind of information we collect and how we use such information, please refer to our Social Media Policy.

4. Who outside Tang Dynasty Tours may see your personal information

To make our business operate effectively and efficiently, and to provide you with the products and services that you expect in order to fulfill our contractual obligations, we need to share your personal information with certain third parties from time to time. We will only share your information for legal, legitimate, necessary, specific and explicit purposes. Below is a list of the third parties to whom we may disclose certain part of your personal data.

4.1 Selected trusted travel business partners

This may include hoteliers, local ground operators, airlines, cruise lines, and other travel-related companies involved in the services we provide you in order to fulfill your booking requirements.

4.2 Competent authorities in jurisdictions in the country you are departing from or about to visit

Before arrival or departure of flights, certain countries including the United States, Canada, the United Kingdom, Australia, China, India, Sri Lanka, etc., require passengers to provide their Advanced Passenger Information (API). API information may include full name, gender, date of birth, nationality, country of residence, visa information, passport details, transit and destination data. We are required by law to offer this information to airlines and transport companies who then transmit it to the relevant authorities.

4.3 Financial organizations and third-party payment agencies

When you make an order, or apply for a refund, we may disclose relevant order information to the financial organizations or third party payment institutions. As we believe fraud detection and prevention are necessary as well as important, we may further share other necessary information with the relevant financial organizations. (The information we may share with these organizations depends on the information you give us when you make a payment. Please see section 2.1.4 for more details.)

4.4 Marketing service providers

Your information may be shared with Google, Facebook, Emarsys and Livechat etc., in order to market our products and services.

4.5 Data analytics service providers

We may also share your data with Google (Google Analytics) and Facebook (Facebook pixel) so as to enhance the experience of our customers.

4.6 Customer review platforms

Some review platforms (e.g. Trustpilot and Feefo) run an invite-only process for posting verified comment, hence customer name and email address are needed before sending customer a review invitation email. We may share such information with these platforms in order for you to leave a review.

4.7 Regulators, agencies of law enforcement or fraud prevention, courts, and any other authorized bodies.

This is to investigate any actual or suspected criminal activity or to comply with a regulation, law, court order, or legal process.

4.8 Any other third parties

If necessary, we may have to share your data with any other third parties for the protection of our or your safety, rights, property, and/or those of other people.

5. International transfer of your information

In order to perform our contract with you, including to provide you with the products and services you book with us, we need to cooperate with our handpicked suppliers in the destinations you are travelling to. Thus we may transfer your information which we consider necessary to these suppliers. Please understand that local laws and regulations in these destinations may not require the same high level of protection for personal information as that provided in your country. However, we will try our best and take necessary steps to have your data protected, e.g. we will make sure the information shared is limited to what is necessary to fulfill our contract with you, or we may use particular contract terms to restrain our local suppliers.

6. Security of your information

We highly value the security of your personal information, and are committed to ensuring the information we hold about you is secure. We are continuously implementing and updating necessary administrative, technical, and physical security measures to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorized access, transmission, storage, processing or disclosure. We will constantly review these measures to ensure that they remain appropriate.

Notwithstanding the above-mentioned security measures, please also understand that there is no such "perfect" security measure for the internet that always works faultlessly. We will do our best to protect your personal information we hold about you with currently available technologies and measures.

7. Retention of your information

Your information we hold about you will be retained for as long as is necessary for us to use this information as set out in this Privacy Policy. As we may use different types of information for different purposes, the applicable retention periods will vary. For instance, your contact details will be retained for a number of years for fulfilling our tax related obligations and/or for providing best possible service for your future bookings, while your payment information will be kept in a shorter period until your payment is completed and confirmed.

8. Your rights to your information

You have a number of rights to your personal information that we hold about you, as described in this section. To exercise any of these rights, you may contact us at .

Your rights include:

• Request access to your personal information.
• Request us to transfer your personal information to you or to a third party that you have chosen.
• Request us to correct any inaccurate or incomplete personal information that we hold about you.
• Request us to erase your personal information.
• Request restriction of processing of your personal information.
• Object to our processing of your personal information.
• Withdraw your previous consent. Please note that the withdrawal of your consent will not affect the lawfulness and validity of any processing activities conducted based on such consent before its withdrawal.

9. Changes to this policy

We reserve the right to modify and update this privacy policy at the time when we consider appropriate. Any changes and updates we make to this privacy policy in the future will be posted on this page, and will become effective once being published. We will note the date of the latest update at the bottom of the content. Please check back frequently to keep up with the latest privacy policy.

This policy was last updated in Oct, 2019.

10. Links to other websites

Our website may contain links to other websites, which we have no control over, and thus cannot be responsible for. This privacy policy does not apply to these other websites. Therefore, once you use the links to leave our website and visit these other websites, you should exercise due caution and check the privacy policy or other policies applicable to these websites.

11. How we use cookies

A cookie is a small text file that is sent from a website and stored on your computer or mobile device by your web browser when you are browsing the website. We use cookies to make our website function properly and efficiently, and ensure you a best possible experience on our website. For more information about how we use cookies and how you can control cookies, please refer to our Cookie Policy.