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PERSONAL DATA PRIVACY POLICY

Effective Date: October 10, 2026


Welcome to the digital space of Chapa Tourism Joint Stock Company (Tax ID: 5300734917, hereinafter referred to as "Chapa"), the management and operation entity of the luxury train brand "Tonkin Heritage Express" (hereinafter referred to as "we", "us", or "our"). This policy transparently outlines how we, acting as the data controller, process the personal information of users visiting our website (https://tonkinheritage.com/) and guests booking itineraries aboard our train.


1. Data Protection Commitment

We strictly adhere to core principles to ensure that the processing of your information is always lawful, fair, and transparent:

  1. Lawfulness and Fairness: Data is collected only with your explicit consent, for the performance of a contract, compliance with legal obligations, or protection of legitimate interests without adversely affecting your rights.
  2. Purpose Limitation and Retention: Information is collected selectively for specific purposes and retained only for the necessary duration.
  3. Transparency and Rights Facilitation: We consistently provide clear information regarding how your data is utilized and facilitate your rights to access, rectify, erase, or object.
  4. System Security: We apply stringent standards to protect the integrity and confidentiality of personal data.
  5. Partner Responsibility and International Transfers: We ensure all third parties accessing data comply with our security protocols; cross-border data transfers are executed with absolute security.
  6. Breach Notification: We are committed to promptly notifying competent authorities and affected individuals in the event of a data breach.


2. Classification of Collected Data

  1. For website users: Title, full name, email, phone number, country, guest category, navigation data, and any information you voluntarily provide when contacting us.
  2. For guests (collected via booking forms or direct communication):
  3. Identification information (Title, full name, date of birth, nationality).
  4. Contact information (Phone number, email, postal address).
  5. Payment information (Credit card details utilized for reservation holds).
  6. Preferences, personalized requests, or itinerary-related notes.
  7. Information regarding accompanying children (if applicable).


3. Purposes and Data Retention Periods


Processing Purpose

Legal Basis

Retention Period

Booking & payment management

Contractual necessity

3 years from the last contact or as required

Handling preferences / special requests

Guest consent

As required

Internal incident management

Legitimate interests

Up to 122 days

Passenger location (emergencies)

Protection of vital interests

Duration of the event

Statistical analysis & service enhancement

Legitimate interests

As required

Satisfaction surveys

Guest consent

3 years from the last contact

Responding to guest inquiries

Legitimate interests

Duration of request processing

Newsletter distribution

Guest consent

Until consent is withdrawn or a maximum of 3 years

Ensuring secure online navigation

Legitimate interests

Maximum of 25 months

Payment fraud prevention

Legitimate interests

90 days for analysis, 2 years for system upgrades. Incident records are retained for 2 years or until resolved.

Legal & accounting obligations

Legal compliance

As required by applicable law

Litigation management

Legitimate interests (establishing evidence)

Statutory limitation periods

Note: If calls with you are recorded, the data will be stored until you request its deletion, or for a maximum of 3 months from the call date.


4. Data Sharing & International Transfers

  1. Data Sharing: Your information may be shared with authorized internal teams (Customer Service, Communications, Legal), service providers (IT hosting, payment gateways, call centers), and competent authorities as required by law.
  2. International Transfers: Data transfers to domestic and international organizations (including countries with varying data protection levels) are strictly secured by Tonkin Heritage Express, utilizing the European Commission's standard contractual clauses and supplementary protective measures when necessary.


5. Data Security Standards

Tonkin Heritage Express implements comprehensive technical and organizational measures (such as firewalls, data encryption, access control, user authentication systems, and physical security protocols) to prevent any risks of destruction, loss, alteration, misuse, or unauthorized access to personal data. Our systems are meticulously designed to maintain confidentiality, integrity, and continuous resilience.


6. Your Exclusive Rights

You possess exclusive rights regarding your personal data, including:

  1. The right to access, rectify, or request the erasure of data.
  2. The right to withdraw consent at any time.
  3. The right to object to data processing for specific purposes.
  4. The right to request data portability.
  5. The right to issue directives regarding the processing of your data post-mortem.

To ensure safety and confidentiality, we may require a monochrome copy of your identification document (ID Card or Passport) to verify your identity before processing requests. You also hold the right to lodge a complaint directly with the competent data protection authority.


7. Information Support & Contact

  1. Management Entity: Chapa Tourism Joint Stock Company (Operating Brand: Tonkin Heritage Express Train).
  2. Address: Lao Cai Station, Khanh Yen Street, Lao Cai Ward, Lao Cai City, Lao Cai Province, Vietnam.
  3. Tax ID: 5300734917.
  4. Email: booking@tonkinheritage.com (Please utilize this address for all data rights inquiries).
  5. Website: https://www.tonkinheritage.com
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