1. Introduction
This website is operated by Zhongrun International (HK) Co., Limited, a company registered in Hong Kong with its desk at Rm 2 LG 1 Mirror Tower, 61 Mody Rd, Tsim Sha Tsui, Hong Kong - 999077, Hong Kong (HK). The site and the travel coordination service described on it are developed and maintained under the developer name Zhongrun Intl. In this Privacy Policy, the words we, us and our refer to the company, and the words you and your refer to any person whose personal information we handle.
Travel coordination involves a great deal of personal information. A delegation itinerary cannot be built without names, passport numbers, dates of birth, nationalities and contact details. A hotel block cannot be held without a rooming list. A visa packet cannot be assembled without the documents that a consulate expects. We therefore take the handling of that information seriously, and this Policy describes the ground rules we apply when we receive it.
Please read this Policy before you send us personal information, whether through the contact form on this website, by email, by telephone or through the documents that you share while planning a delegation. If any part of this Policy is unclear, you are welcome to write to us and ask for a plain explanation.
2. Who We Are
Zhongrun International (HK) Co., Limited is the controller of the personal information described in this Policy. Our registered and operating address is Rm 2 LG 1 Mirror Tower, 61 Mody Rd, Tsim Sha Tsui, Hong Kong - 999077, Hong Kong (HK). Our contact email address is office@zhongrunintl.buzz and our contact telephone number is +14583125819. The developer name for this website is Zhongrun Intl.
We act as a data user for our own service records, and in many delegation projects we also act as a processor on behalf of the organising body that engaged us. When we act as a processor, the organising body decides the main purposes and the scope of the processing, and we follow its written instructions. Where a question concerns the wider purposes of a delegation programme, the organising body is usually the right party to answer it, and we will point you to it when that is the case.
We do not run a data brokerage. We do not build profiles of travellers for resale. We do not rent, sell or trade personal information to advertising networks. The information we hold exists to move a delegation from one city to another with the correct rooms, papers and transfers in place.
3. Scope of This Policy
This Policy applies to personal information that we collect through this website, through email and telephone contact with our desk, and through the planning and delivery of travel coordination services. It does not apply to information that a third party collects on its own account, including hotels, airlines, ground transport operators, consulates and online booking platforms that you may approach directly.
The Policy covers both digital records and paper records. A rooming list printed for a delegation leader, a visa packet submitted to a consulate and a per diem reconciliation sheet held in a folder are all covered in the same way as an email or a spreadsheet. The medium does not change the duty of care.
Where we provide a service to an organisation, that organisation may have its own privacy notice that applies to your relationship with it. This Policy describes our own handling and does not replace any notice that your employer, university or association is required to give you. If the two documents appear to conflict on a point about your rights, the more protective position should be assumed, and you may contact us to clarify.
4. Information We Collect
The information we collect falls into several practical groups. We list them here in plain terms so that you can see what a delegation file typically contains.
Identity and contact information
Full name as it appears on the travel document, preferred name, job title, employer or institution, email address, telephone number and, where relevant, a messaging handle. For delegation leaders we also record the name of the person who signs off on changes.
Travel document information
Passport number, issuing country, expiry date, nationality, place of birth, date of birth, gender as recorded on the passport, and any previous visa details needed to complete an application. For some destinations we also need a scanned copy of the passport information page and a photograph that meets the local specification.
Travel and accommodation details
Flight numbers, arrival and departure times, seat preferences where they affect transfer planning, hotel room requirements, sharing arrangements, accessibility needs, dietary requirements for group meals and any loyalty numbers that a traveller asks us to apply to a booking.
Payment and settlement information
Billing contact names, invoice addresses, purchase order references, bank details for settlement where a supplier requires them, and per diem receipts submitted for reconciliation. We do not store full card numbers in our own systems. Where a card is used, the payment is processed by a regulated payment provider and we receive only the confirmation and the last four digits.
Correspondence and file notes
Emails, messages, call notes and version notes attached to a delegation file. These records matter because they show what was agreed and when a change was requested, and they protect both the organiser and the desk if a dispute arises later.
Website technical information
When you visit this website, our hosting infrastructure may record standard server log information such as the requested page, the time of the request, the referring page and a truncated network address. This information is used for security and reliability and is not combined with delegation files.
5. How We Collect Information
We collect most information directly from you or from the organiser of the delegation. A delegate may send passport details through an email attachment, an organiser may share a spreadsheet of names and dates, and a finance officer may forward receipts for reconciliation. In each case the information arrives because it is needed for a specific step in the plan.
Some information comes from suppliers. A hotel may confirm the names on a room block, a ground transport operator may confirm which driver was assigned to a run, and an airline may confirm that a ticket was issued. We record these confirmations so that the delegation file remains accurate at the point of travel.
A smaller amount of information comes from public or official sources. For example, we may check a consulate website for current document requirements or a venue website for an address. We do not gather personal information about travellers from social media or from data brokers, and we do not ask suppliers to do so on our behalf.
Where an organiser shares a list of travellers with us, the organiser is responsible for making sure that each traveller knows their details are being passed to a travel coordinator. We ask organisers to include a short notice in their own communications, and we are happy to supply a template paragraph for that purpose.
6. Why We Use Information
We use personal information to deliver the services described on this website. In practical terms, that means planning itineraries, holding hotel blocks, preparing visa papers, building transfer rosters, sourcing meeting rooms and reconciling per diem. Each of these activities requires a specific set of details, and we try not to collect more than the activity needs.
We also use information to communicate with you about a file. A coordinator may call a delegate to confirm an arrival time, email an organiser with a revised version of the itinerary, or message a driver with a changed pickup point. These communications are part of the service and are not marketing.
Other uses include keeping financial records, responding to complaints, meeting our legal and accounting obligations, protecting the security of our systems and improving the way the desk works. When we review a completed file to see what could be improved, we remove names and contact details first wherever that is practical.
7. Our Lawful Bases
Depending on the circumstances, we rely on one or more of the following bases for processing personal information.
- Performance of a contract. Most delegation work is carried out under an agreement with an organising body, and the processing is necessary to perform that agreement.
- Legitimate interests. We have a legitimate interest in running a safe, accurate and efficient travel desk, in protecting our systems and in responding to enquiries. We balance that interest against your rights and expectations.
- Consent. Where we need to use information for a purpose that is not covered by the service, such as adding you to a newsletter list, we ask for your consent first and you may withdraw it at any time.
- Legal obligation. We may need to keep records for tax, accounting or regulatory purposes, or to respond to a lawful request from an authority.
- Vital interests. In an emergency involving a traveller, we may share limited details with medical or emergency services where it is necessary to protect someone.
Where we rely on legitimate interests, you have the right to object, and we will stop the relevant processing unless we can show compelling grounds that override your objection or unless the processing is needed for a legal claim.
8. Delegation and Traveller Data
A delegation file is usually created by an organiser who is our client. The travellers themselves may never contact us directly. This creates a layered relationship, and we handle it in a layered way.
When we receive a traveller list, we check that it matches the passport data provided and we flag any mismatch rather than correcting it silently. A name that differs by a single letter from the passport can cause a visa refusal or a denied boarding, so accuracy at the intake stage saves a great deal of trouble later. The organiser confirms the corrected list before any booking is made.
Special category information sometimes appears in a delegation file. A traveller may require a wheelchair accessible room, a specific medical diet or assistance at an airport. We record only what is needed to arrange the service, we mark it as sensitive in the file, and we share it only with the supplier who must act on it. We do not record medical diagnoses, and we ask organisers to describe the requirement rather than the condition where that is sufficient.
Travellers may ask us directly what information we hold about them. We will usually refer the request to the organiser first, because the organiser controls the file, but we will always confirm whether we hold the information and we will cooperate with a lawful request for access.
11. International Transfers
Delegations cross borders, and so does their paperwork. A hotel in another city, a consulate in the traveller country of origin and an airline operating a connecting route may all receive parts of a delegation file. When we transfer personal information outside Hong Kong, we take steps to ensure that it remains protected.
Those steps include using suppliers who are bound by written data protection terms, limiting the transfer to the information that the recipient actually needs, and requiring the recipient to apply appropriate security measures. Where a transfer involves a country with a different legal regime, we consider the nature of the information and the risk of harm before the transfer takes place.
If you would like to know more about the safeguards that apply to a specific transfer, you may contact us and we will explain the arrangement in plain terms, subject to any confidentiality obligation we owe to another party.
12. How Long We Keep Information
We keep personal information only for as long as it is needed for the purpose for which it was collected, or for as long as the law requires. In practice, our retention follows the shape of a delegation file.
| Record type | Typical retention |
|---|---|
| Enquiries that do not become bookings | Twelve months from the last contact |
| Delegation itineraries and rooming lists | Up to three years after the final settlement |
| Visa packets and passport copies | Six months after the visa decision, then deleted |
| Financial records and per diem reconciliation | Seven years, in line with accounting practice |
| Server logs | Ninety days |
When a retention period ends, we delete the record or, where deletion is not practical, we remove the identifying details so that the remaining record can no longer be linked to a person. Paper copies are shredded. Backups are overwritten in the normal course of our backup cycle.
Some records are kept longer where a dispute is active, where a legal hold applies or where an authority has asked us to preserve information. In those cases we keep only what the situation requires and we review the hold regularly.
13. How We Protect Information
We apply organisational and technical measures that are proportionate to the sensitivity of the information we hold. Access to delegation files is limited to the coordinators working on them and to the supervisors who review the desk. Each person with access uses their own account, and shared logins are not permitted.
Digital files are stored in access controlled systems with encryption in transit and at rest. Passport scans and visa packets are held in a restricted folder that is separate from general correspondence. Paper files are kept in locked storage at our office and are collected at the end of each working day.
We train our staff on handling personal information, on recognising phishing attempts and on the correct response when a device is lost. We test our backup process so that a file can be recovered if a system fails. We review access rights when a person leaves the desk and remove them on the same day.
No system is completely secure. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the relevant authority and the affected parties without undue delay, and we will describe what happened, what we have done and what you can do to protect yourself.
14. Your Privacy Rights
Subject to the law that applies to you, you may have the following rights in relation to your personal information.
- Access. You may ask for a copy of the personal information we hold about you.
- Correction. You may ask us to correct information that is inaccurate or incomplete.
- Deletion. You may ask us to delete information that we no longer need for the purpose it was collected for.
- Restriction. You may ask us to stop using information while a question about its accuracy or use is resolved.
- Objection. You may object to processing that we carry out on the basis of legitimate interests.
- Portability. Where the law provides it, you may ask for a copy of information you gave us in a structured and commonly used format.
- Withdrawal of consent. Where processing is based on consent, you may withdraw that consent at any time.
To exercise a right, write to office@zhongrunintl.buzz with enough detail for us to identify the record and verify that you are the person concerned. We may ask for proof of identity where the request involves sensitive information. We respond within the period required by the applicable law, and we will tell you if we need more time.
If your request concerns a delegation file controlled by an organising body, we may need to refer the matter to that body first. We will tell you when we do so, and we will still assist with the part of the record that we control. If you are not satisfied with our response, you may complain to the privacy authority in your jurisdiction, and we will cooperate with any investigation.
15. Privacy for Children
Our services are directed at organisations and adult travellers. We do not knowingly collect personal information from children through this website, and we do not market to children.
A delegation may occasionally include a minor, for example a student group or a family member travelling with an adult participant. In that case the minor information is provided by the organiser or by a parent or guardian, and it is used only to arrange travel and accommodation. We ask that organisers obtain consent from a parent or guardian before sharing a minor details with us.
If we learn that we have collected information about a child without appropriate consent, we will delete it promptly. A parent or guardian who believes that a child has provided information to us may contact us and we will investigate.
16. Marketing and Contact Choices
When you contact us about a delegation, we use your details to respond to that enquiry. We do not add you to a marketing list as a condition of getting an answer. If we ever send a seasonal note about desk availability, it will be a short message that you can stop with a single reply, and the option to stop will be included in the message itself.
You can tell us at any time that you do not want to receive anything other than messages about an active file. We will record the choice against your contact details and we will honour it across the desk. Operational messages that are necessary to deliver a service, such as a change to an itinerary, are not marketing and will continue while the file is active.
17. Third Party Links and Services
This website may link to third party sites, including hotel websites, transport operators and official consulate pages. Those sites have their own privacy notices, and we do not control how they collect or use information. We encourage you to read the notice on any site before you submit personal details to it.
We may use a small number of service providers to support the desk, such as a hosting provider, an email provider and an accounting system. These providers are selected for their reliability and are bound by written terms that require them to protect the information they handle and to act only on our instructions.
18. Changes to This Policy
We review this Policy from time to time to reflect changes in the way the desk works, in the services we offer or in the law that applies to us. When we make a material change, we will update the effective date at the top of this page and, where the change affects an active delegation, we will tell the organiser directly.
We encourage you to read this Policy again when you start a new project with us, because the version in force at that time is the one that applies. Earlier versions are kept in our records so that we can explain how a past file was handled.
19. How to Contact Us
If you have a question about this Policy, a request about your personal information or a concern about the way we have handled a file, please contact us using the details below. We read every message and we aim to reply within two working days.
Zhongrun International (HK) Co., Limited
Rm 2 LG 1 Mirror Tower, 61 Mody Rd, Tsim Sha Tsui, Hong Kong - 999077, Hong Kong (HK)
Email: office@zhongrunintl.buzz
Telephone: +14583125819
Developer: Zhongrun Intl
If you are not satisfied with our response, you may escalate the matter in writing to the same address and mark your message for the attention of the desk supervisor. We will review the file and reply with a full explanation of what we found and what we propose to do.