Privacy Policy

1. Who is responsible for your data

The data controller is Shanghai Niuou Tourism Consulting Co.,Ltd (registered office: Building 4, No. 686 Nanfeng, Fengcheng, Fengxian District, Shanghai, China; customer service center: Corso S. Gottardo, 22, 20136 Milano MI, Italy). You can reach us at info@silkstar.travel.

[TODO: company registration number / unified social credit code.]

[TODO: name and contact details of our representative in the EU under Article 27 GDPR, if required.]

2. What data we collect

• Enquiry form: your name, email address, phone number (optional), the journey you are interested in, number of travellers and your message.
• Mystery journey quiz: your answers to the quiz and your contact details.
• Email sign-ups (for example the 10% discount offer): your email address, your language, where you signed up and whether you agreed to receive marketing emails.
• Emails you send us: your address and the content of your message.
• Technical data: when you open the site, our hosting provider processes your IP address and basic request details in server logs, and uses the country of your IP address to choose the language of the site (Italian for Italy, French for France, English elsewhere). We do not store this for any other purpose.

3. Why we use your data, and on what legal basis

• To answer your enquiry and prepare a proposal for your journey: steps taken at your request before a contract (Article 6(1)(b) GDPR) and our legitimate interest in replying to you (Article 6(1)(f)).
• To send you a discount code, travel inspiration and offers by email: your consent (Article 6(1)(a)). You can withdraw it at any time by using the unsubscribe link or writing to us.
• To run, secure and improve the website, including choosing the language: our legitimate interest (Article 6(1)(f)).
• To meet legal, tax and accounting obligations: Article 6(1)(c).

4. Who we share data with

We use service providers who process data on our behalf and only on our instructions:

• Vercel Inc. — website hosting.
• Sanity AS — content management and storage of email sign-ups.
• Resend — sending the emails triggered by our forms.
• Zoho Corporation — our business mailbox.

If you book a journey, we will also share the details needed with the hotels, guides and transport partners who deliver it. We do not sell your personal data.

5. Transfers outside your country

We are based in China and some of our providers are in the United States and elsewhere, so your data may be transferred outside the European Economic Area.

[TODO: describe the safeguards used, for example standard contractual clauses or an adequacy decision.]

6. How long we keep data

[TODO: confirm retention periods.] In general we keep enquiry data for as long as needed to handle and follow up your request and for [TODO: period] afterwards, and email sign-up data until you unsubscribe.

7. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected and, in certain cases, deleted;
• restrict or object to our processing;
• receive your data in a portable format;
• withdraw your consent at any time, without affecting the processing done before.

To exercise these rights, write to info@silkstar.travel. You may also lodge a complaint with your data protection authority, for example the Garante per la protezione dei dati personali (Italy) or the CNIL (France).

8. Cookies

Our website does not use analytics or advertising cookies. See our Cookie Policy, linked in the footer, for the small amount of information stored on your device.

9. Children

Our services are not directed at children under 16 and we do not knowingly collect their data.

10. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last changed.

11. Contact

Shanghai Niuou Tourism Consulting Co.,Ltd — registered office: Building 4, No. 686 Nanfeng, Fengcheng, Fengxian District, Shanghai, China; customer service center: Corso S. Gottardo, 22, 20136 Milano MI, Italy — info@silkstar.travel