Privacy Policy

Updated on: 31 May 2023

 

The Purpose of these Rules

Shanghai Miao Travel & Exhibition Co., Ltd. and its related party, Destination Sport Co. Ltd., trading as “Marathon Tours & Travel, China”, itself being a subsidiary of Destination Sport Group, registered in Manchester (UK) and parent company of Marathon Tours & Travel (USA) (referred to herein, as "Miao Travel", "we", "us"), are committed to protecting and maintaining the security of your personal information.

 

This Privacy Policy applies to the website (https://www.marathontours.com.cn) operated and maintained by us and the "MarathonToursCN" WeChat official account platform (hereinafter collectively referred to as the "Platform").

 

Through this Privacy Policy, we would like to inform users of the Platform (hereinafter collectively referred to as "you") about how we collect and process personal information and inform you of your rights.

 

We understand the importance of processing personal information to you and strictly comply with the relevant legal provisions. Protecting your personal information is important to us and our partners. We promise that the processing of your personal information complies with the Personal Information Protection Law of the People's Republic of China (hereinafter referred to as the "PIPL"), the Information Security Technology Personal Information Security Specification (GB/T 35273-2020) and relevant applicable data protection rules.

 

This Privacy Policy may be supplemented by additional privacy notices, terms, agreements or notices provided to you.

 

This policy will help you understand the following:

 

Article 1: Basic principles of data processing

Article 2: Collection of Personal Information

Article 3: Sharing, Transfer and Public Disclosure of Personal Information

Article 4: Personal information storage and retention periods

Article 5: Data Protection of Minors

Article 6: Data Subject Rights

Article 7: Data security protection measures

Article 8: Use of Cookies and Similar Technologies

Article 9: Security commitments of affiliates and partners

Article 10: The name and contact information of the responsible institution

Article 11: Continuous update of the statement

Article 12: Prevailing Language Clause

 

Article 1 Basic principles of data processing

We process your personal information in strict accordance with applicable law and the following basic principles:

·  The processing of personal information will always follow the principles of legality, propriety, necessity, and good faith, and will not process personal information through misleading, fraud, coercion, etc.

· The processing of personal information always has a clear and reasonable purpose, is directly related to the purpose of processing, and adopts a method that has the least impact on the rights and interests of individuals.

·  The processing of personal information always follows the principle of openness and transparency, discloses the rules for processing personal information, and clearly indicates the purpose, method, and scope of processing.

· Always ensure the quality of personal information when handling personal information and avoid adverse effects on personal rights and interests due to inaccurate and incomplete personal information. 

 

Article 2 Collection of Personal Information

"Personal Information" means all kinds of information relating to an identified or identifiable natural person recorded electronically or otherwise, excluding anonymized information. The processing of personal information includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of personal information.

 

"Individual" under this Privacy Policy is the user of the Platform.

 

In general, we do not collect your personal information directly. Your personal information will only be collected and processed for the purposes described in this Policy.

 

- Purpose of collection

· Required for account registration.

· Necessary for the provision of hotel reservation services.

· Provide necessary personal information to the competition organizers.

· To send you marketing messages.

· Provide customer service consultation and after-sales service.

· Laws, regulations, and compliance requirements

We may need to use your information to handle and resolve legal disputes, or to comply with any laws and regulations binding on us or documents issued by regulatory authorities, to cooperate with national authorities or regulatory authorities in investigating and complying with laws and regulations.

 

- How do we collect your personal information?

· When you use our platform, you voluntarily submit your personal information or otherwise authorize us to collect your personal information.

· When using, transmitting, sharing, and storing data with a third party that has promised to have obtained legal authorization (atypical scenarios).

· Other methods legally authorized by you.

 

- What types of personal information do we collect and process?

When you use our Platform, or when you have promised to obtain legally authorized third parties to authorize us to use your personal information, we may collect the following personal information about you:

 

	Categories of user personal information	Specific content of personal information
A.	Identity information	For example: name, gender, nationality, type and number of documents, date of birth, passport number and expiry date
B.	Contact information	For example: phone number, email
C.	Financial information	For example: bank cards, bank accounts, payment amounts, billing information
D.	Technical information	For example: login data, IP address, cookies, browser type, mobile phone model

 

- Exceptions to the collection and use of personal information

In the following circumstances, we may not need your authorization and consent for the collection and use of information involved:

 

· In connection with our performance of our obligations under laws and regulations.

· Directly related to national security and national defense security.

· Directly related to public safety, public health, and major public interests.

· Directly related to criminal investigation, prosecution, trial, and execution of judgments.

· For the purpose of safeguarding your or other individuals' life, property and other major legal rights and interests, while it is difficult to obtain your consent.

· The personal information collected is disclosed to the public by yourself.

· Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

· Necessary for the conclusion and performance of a contract at your request.

· Necessary for maintaining the safe and stable operation of the products or services provided.

· Other circumstances stipulated by laws and regulations.

 

Article 3 Sharing, Transfer and Public Disclosure of Personal Information

We respect your personal privacy and comply with relevant laws and regulations; we promise to keep your personal information strictly confidential and will not sell your personal information to others.  On the basis of confirming the personal information protection system and transmission security of the third party, we may disclose relevant information and materials to the relevant third party only to perform the contract (such as a service contract), obtain consent or otherwise permitted by law.

 

- Data sharing

We will use your personal information and share it with the following affiliates or partners as follows:

 

 

- Data Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

· Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.

· In the event of a merger, acquisition, or bankruptcy liquidation, if the transfer of personal information is involved, we will require the company or organization that holds your personal information to continue to be bound by this Privacy Policy, otherwise we will require the company or organization to seek authorization and consent from you again.

 

- Public disclosure

We will only publicly disclose your personal information under the following circumstances:

· With your explicit consent.

· Disclosure based on law:

· We may publicly disclose your personal information under the circumstances of laws, legal procedures, litigation, or mandatory requirements of government authorities.

 

Article 4 Personal information storage and retention periods

Generally, we will store personal information collected from the People's Republic of China within the territory of the People's Republic of China. We will not provide personal information outside the People's Republic of China. However, in special scenarios where you book overseas hotels, we need to provide your personal information to overseas hotels. When we provide personal information outside the People's Republic of China, we will inform you of the name or surname of the overseas recipient, contact information, purpose of processing, processing method, type of personal information, and the methods and procedures for you to exercise the rights stipulated in the PIPL to the overseas recipient, and obtain your separate consent.

 

We will not retain your personal information longer than is reasonably necessary or required by law.  How long we keep it depends largely on the type and purpose of the information. The criteria we use to determine retention periods for certain categories of data are as follows:

 

· Whether the purpose of collecting and processing personal information has been achieved.

· whether there is a contractual or legal obligation to retain data for a period of time.

· whether there are any ongoing legal claims or relating to your relationship with us.

· whether there are any applicable laws, rules or regulations that allow for a specific retention period.

· Whether personal information is considered sensitive personal information, in which case a shorter retention period will normally apply.

 

Article 5 Data Protection of Minors

We do not directly provide products or services to minors under the age of 18, nor do we actively collect their personal information.

 

If we find that our products or services have inadvertently collected the data of minors without parental permission, we will take necessary measures to deal with it as soon as possible in accordance with applicable laws.

 

Article 6 Data Subject Rights

We will ensure and promote the exercise of the rights of personal data subjects in accordance with Chapter IV of the PIPL.

 

- Right to information

This Privacy Policy will explain to you the specifics of our use of your personal information.  In addition, we also require third parties such as our customers and partners to disclose the relevant use of personal information to you to obtain your legal authorization.

 

- Right to decision (right to restriction of processing)

In certain circumstances, you have the right to ask us to restrict the processing of your personal information.  For example, when concerned about the accuracy or use of your personal information, you may request to limit the way we use your personal information.

 

In addition, when we find that there is no legal basis for processing your personal information, we will stop processing your personal information immediately as much as possible and notify you and relevant parties of the processing results in a timely manner.

 

- Right of access, right of reproduction

You have the right to access and request a copy of your personal information.  However, due to legal and contractual provisions, there may be exemptions and limitations of rights, which means that you may not have access to all your personal information collected and processed by us.  We will notify you of any waivers or limitations that apply and their impact.

 

In addition, before you exercise the right of access and copying, we may use appropriate verification procedures to verify your subject's identity to comply with data security requirements.

 

- Right to portability

You have the right to obtain the personal information you have provided to us.  You also have the right to request that we transfer your personal information to another organization if you have given your explicit consent, or if it is necessary for the performance of an agreement, or if the processing is carried out by automated means.

 

- Right to rectification

In certain circumstances, you have the right to request that we correct personal information that you believe is inaccurate or incomplete. We will respond to your request within a reasonable period of time and promptly notify you of the result of the correction or the reason why it cannot be corrected.

 

- Right to erasure

In certain circumstances, you have the right to request that we delete your personal information.  Where appropriate, we will comply with your request and will implement it within thirty days and inform you of the outcome and justification.

 

Please note that based on audit, compliance, security backup, operation, and maintenance needs, we may retain some of your personal information, such as account information, etc.

 

- Right of withdrawal

In certain cases, you have the right to revoke your consent. The withdrawal of consent does not affect the lawfulness of processing carried out or being carried out on the basis of consent until it is revoked.

 

- Right to explanation

You have the right to request us to explain the rules for processing personal information through the contact information we provide in this Privacy Policy.

 

- Right to close relatives of deceased users

If you are a close relative of a deceased user of this platform, you can exercise the rights of access, copy, correction, and deletion of the relevant personal information of the deceased user for your own legitimate and legitimate interests; However, unless the deceased user made other arrangements before his death.

 

- To respond to your above requests

For security purposes, you may be required to provide a written request or otherwise to prove your identity. We may ask you to verify your identity before processing your request.

 

We will respond within thirty days. If you are not satisfied, you can also complain through our official customer service number.

 

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may refuse requests that are unreasonably repetitive, require excessive technical means (for example, need to develop new systems or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are very impractical.

 

In the following circumstances, we will not be able to respond to your request in accordance with the requirements of laws and regulations:

 

· Directly related to national security and national defense security.

· Directly related to public safety, public health, and major public interests.

· Directly related to criminal investigation, prosecution, trial and execution of judgments.

· There is sufficient evidence that you have subjective malice or abuse of rights.

· Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.

· Involving trade secrets.

 

Article 7 Data security protection measures

We have taken the necessary technical and organizational measures to protect your data against possible dangers, such as against unauthorized access, unauthorized modification or distribution, damage, destruction, or misuse.

 

We use Alibaba Cloud platforms to store your personal information, and Alibaba Cloud platforms have built-in firewalls.  Alibaba Cloud Platform also performs security control over access-to-access ports. In addition, we regularly update the administrator password to ensure data security.

(Alibaba Cloud Platform Privacy Policy See http://terms.aliyun.com/legal-agreement/terms/)

 

Article 8 Use of Cookies and Similar Technologies

Cookies and similar technologies are commonly used technologies on the Internet. When you use our services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device to collect and store personal information when you access and use this product. We use cookies and similar technologies mainly to ensure the safe and efficient operation of products and services.

 

We may set authentication and security cookies or anonymous identifiers to enable us to confirm whether you are logged in securely, or if you have encountered illegal activities such as theft and fraud. These technologies also help us improve service efficiency, login, and responsiveness.

 

We promise that we will not use cookies for any purpose other than those described in this Privacy Policy.

 

Article 9 Security commitments of affiliates and partners

We require affiliates and partners to strictly comply with our data protection rules, as well as relevant data protection regulations.  At the same time, they are required to obtain the legal authorization of the individual before collecting and processing data and urge them to continue to fulfill this obligation. If you find that our customers and partners may have violated personal information protection agreements, you can contact us to deal with it.

 

Article 10 The name and contact information of the responsible institution

If you wish to contact us regarding your personal information or this Privacy Policy, you may contact us at sales@marathontours.cn

 

Destination Sport Co. Ltd

Address: Office 604-09, 6F, Shanghai Centre West Wing, No. 1376 Nanjing West Road, Shanghai

Zip: 200040

 

Phone: 13910715809

 

Article 11 Continuous update of the statement

This Privacy Policy is effective as of the date set forth at the end of this Privacy Policy.

We reserve the right to modify this Privacy Policy at any time, so please be sure to check it frequently.

If we make material changes to this Privacy Statement, we will notify you by providing a prominent notice via email, our website and app homepage, etc.

 

Article 12 Prevailing Language Clause

In case of dispute, the Chinese language version of this document prevails.

 

Effective date of this Privacy Policy: 31 May 2023

Last revision date: 31 May 2023