01Who we are
HeartEase is the trading name of Jiangxi Heyi International Travel Agency Co., Ltd. (江西和易国际旅行社有限公司), a travel agency licensed in the People's Republic of China and founded in 2002.
- Registered address
- 2 Hongcheng Road, Qingyunpu District, Nanchang, Jiangxi 330002, China
江西省南昌市青云谱区洪城路2号 - Unified Social Credit Code
- 91360102MA39A39C9X
- Travel agency licence no.
- L-JX-100264
- Privacy contact
- contact@heyitravel.cn
We are the controller (under the EU/UK GDPR) and the personal information handler (under China's Personal Information Protection Law, "PIPL") for the information described here.
02What this policy covers
This policy covers www.hearteasetravel.com and every way you reach us: our enquiry form, email, WhatsApp, Telegram, WeChat, and bookings that come to us through travel platforms such as Viator, GetYourGuide, Trip.com and Klook.
When you book through one of those platforms, the platform collects your information under its own privacy policy and passes us what we need to run your tour. This policy governs what we do with it from that point on.
03What we collect
When you enquire. Your name, email address, country, intended travel dates, and whatever you tell us in your message.
When you book. Passport name, passport number, nationality, date of birth and passport expiry; the type of entry permit you hold (for example a visa, a visa-free entry, a 240-hour visa-free transit entry, or a Home Return Permit); flight or train details; your phone number and preferred messaging app; hotel and room preferences; and the names and details of anyone travelling with you.
Information that needs extra care. Dietary requirements, allergies, mobility or accessibility needs, medical conditions relevant to your safety on tour, and your emergency contact. Your passport number is also treated as sensitive. We ask for these only where they are needed to run your tour safely, and we ask for your separate consent before we use them (see Section 5).
Payment. We do not see or store your card number. Payments are handled by PayPal, or by the travel platform you booked through.
When you use our website. Our web server records standard technical information such as your IP address and browser type. We do not use analytics, advertising or tracking cookies.
When you give us feedback. Reviews, photographs and testimonials, if you choose to share them.
04Why we use it, and on what legal basis
| What we do | Why | Legal basis (GDPR) | Legal basis (PIPL) |
|---|---|---|---|
| Answer your enquiry and prepare a quotation | To respond to you | Steps at your request before a contract | Necessary to conclude a contract at your request |
| Book hotels, guides, drivers, tickets, restaurants and experiences | To deliver the tour you bought | Performance of a contract | Necessary to perform a contract |
| Give your passport details to hotels, airlines and China Railway | Chinese law requires it. Hotels must register foreign guests with the local Public Security Bureau, and rail and air tickets are issued against passport data | Legal obligation | Necessary to comply with a legal obligation |
| Keep accounting and tax records | Chinese tax and accounting law requires it | Legal obligation | Necessary to comply with a legal obligation |
| Handle a complaint, claim or insurance matter | To resolve it and defend our position | Legitimate interests | Necessary to perform a contract / legal obligation |
| Send you our newsletter or offers | Only if you asked for them | Consent | Consent |
| Use your photograph or review in our marketing | Only if you agreed | Consent | Consent |
Under PIPL there is no "legitimate interests" basis. Where we process your information in China, we rely on your consent or on the necessity of performing our contract with you.
05Your separate consents
Chinese law asks us to obtain your separate, specific consent — not just your acceptance of this policy — for three things. We ask for each of them individually on our booking form:
- Sensitive personal information. Your passport number, and any dietary, medical, accessibility or emergency-contact information you give us.
- Sending your information outside mainland China. See Section 7.
- Sharing your information with the suppliers who deliver your tour. See Section 6.
You may withdraw any of these consents at any time by emailing contact@heyitravel.cn. Withdrawing consent does not undo what we did lawfully beforehand. If you withdraw consent for information we need in order to run your tour, we may not be able to deliver the booking, and our cancellation terms will apply.
07Sending information across borders
We are a Chinese company. Your information is stored and processed in mainland China.
If you are in the EEA, the UK or Switzerland, sending your booking details to us is a transfer to a country that has not received an adequacy decision. We rely on the exception for transfers that are necessary to perform the contract you asked us for — we cannot book your hotel room without giving the hotel your name and passport number. We want to be plain with you: once your information is in China, it is subject to Chinese law, including provisions that allow state authorities to require access to data in defined circumstances. If you would rather not accept that, please do not send us a booking; a travel platform such as Viator or GetYourGuide may be a better route for you.
For anything that is not necessary to run your trip — our newsletter, for example — we will only send your information to China with your explicit consent, given after reading this section.
Information leaving China. Our email is hosted with Tencent in mainland China, so ordinary correspondence stays there. Some of the other tools we use sit outside mainland China. Where that applies:
| Recipient | Location | What they get | Why |
|---|---|---|---|
| Viator / GetYourGuide / Trip.com / Klook | Various | Booking and traveller details | To manage bookings you made on their platform |
| PayPal | United States | Payment details | To take payment |
You may exercise your rights (Section 10) directly against these recipients, and we will help you do so. Contact us at contact@heyitravel.cn.
09How long we keep it
- Enquiries that don't become bookings: 12 months, then deleted.
- Booking records: for the duration of your trip and for as long afterwards as we may need to handle a complaint or claim, and thereafter for the periods required by Chinese tax and accounting law.
- Marketing contacts: until you unsubscribe.
- Photographs and reviews used in marketing: until you ask us to stop.
10Your rights
10.1Everyone
Whoever you are and wherever you live, you can ask us to show you what we hold about you, correct it, delete it, or stop using it. Email contact@heyitravel.cn. We will reply within 30 days. We do not charge for this and we will not treat you differently for asking.
10.2If you are in the EEA or UK
You have the rights of access, rectification, erasure, restriction of processing, data portability, objection to processing, and withdrawal of consent. You also have the right to complain to your national data protection authority. We have not appointed an EU or UK representative under Article 27.
10.3If you are in California
We are not a "business" as the CCPA defines it — we fall below all three of its thresholds. We are telling you our position anyway: we do not sell or share your personal information, we do not disclose it for cross-context behavioural advertising, and we will honour access and deletion requests from you exactly as we would from anyone else.
10.4If you are in mainland China
Under PIPL you have the right to know about and decide on the handling of your personal information; to access and copy it; to have it transferred to another handler; to correct or delete it; to withdraw consent; to ask us to explain our handling rules; and, in the case of a deceased person, for close relatives to exercise these rights.
11Children
We do not market to children. Bookings are made by adults. Where a booking includes a child, the booking adult provides the child's details and confirms they are entitled to do so. Under Chinese law, the personal information of anyone under 14 is sensitive and requires a parent's or guardian's consent, which we treat the booking adult as giving.
12Security
We limit access to your information to the people who need it, we send passport data to suppliers over secured channels rather than in plain email where we can, and we require our suppliers to protect what we give them. No system is perfect, and we will not pretend otherwise. If a breach affects you, we will tell you and the relevant authorities as the law requires.
13Changes
We will post any change here with a new date and version number. If a change matters — a new recipient, a new purpose — we will tell you before it takes effect and, where the law requires consent, we will ask for it.
14Contact and complaints
contact@heyitravel.cn — a person reads this, and we would rather hear from you than from a regulator. If we cannot resolve your concern, you may complain to your national data protection authority, or, in China, to the Cyberspace Administration of China.
Also in Legal · 条款
Terms — Website Use & Booking Conditions
Jiangxi Heyi International Travel Agency Co., Ltd. (HeartEase / 和易)
Travel with Heart, Discover with Ease.
contact@heyitravel.cn · www.hearteasetravel.com