Privacy Notice

Last Updated: October 1, 2025

I. Introduction

The White Project Travel Limited (“TWP”, “we”, “us”, or “our”), a company incorporated under the laws of Hong Kong Special Administrative Region (HKSAR), recognizes the importance of protecting your privacy.
This Global Privacy Notice (“Notice”) explains how we collect, process, use, disclose, and safeguard personal information about guests (“Guest Personal Data”).
It also describes your rights and choices regarding that information and other relevant details about our data practices.
This Notice applies to all websites, online platforms, and offline activities operated by The White Project Travel Limited.

TWP may act as either a data controller, data processor, or both, depending on the circumstances, in relation to the collection and processing of Guest Personal Data.
We are committed to handling your information responsibly and in accordance with applicable privacy laws in Hong Kong and any other jurisdiction in which we operate.

We have appointed a Data Protection Officer responsible for overseeing questions related to this Notice.
If you have questions about this Notice, including any requests to exercise your legal rights, please contact us using the details below.

II. Contact Details

Legal Entity: The White Project Travel Limited
Registered in: Hong Kong SAR
Email: contact@thewhiteproj.com
Postal Address: Suite A28, Level 7, K11 ATELIER, Salisbury Rd, Tsim Sha Tsui, HK
Attention: Data Protection Officer

This Notice is written in English. If a translation causes any discrepancy, the English version shall prevail.

III. How Data Is Collected

1. Information You Provide to Us

We collect Guest Personal Data that you provide directly when you:

  • interact with our website or other digital services,

  • make an enquiry, reservation, or booking,

  • communicate with our staff (including customer service, marketing, or sales),

  • or participate in promotions, surveys, or events.

Examples include your name, contact details, booking preferences, payment information, health or accessibility needs, and any correspondence.

2. Information Collected Automatically

When you visit our website or use Wi-Fi provided by TWP, we may automatically collect:

  • Device identifiers, IP address, browser type and operating system;

  • Location information (approximate, not precise);

  • Browsing activity such as pages viewed, links clicked, and previous visits.

We use cookies and similar technologies to understand visitor behavior and improve our websites.
For details, see our Cookie Notice below.

3. Information Obtained Indirectly

We may receive Guest Personal Data from:

  • travel agents, referral partners, or marketing vendors who provide data lawfully;

  • social media platforms when you interact with us there;

  • service providers acting on our behalf (e.g., payment processors, analytics companies).

4. Minors’ Privacy

Our services are not intended for individuals under 18 years of age (“minors”).
We do not knowingly collect data from minors without parental or guardian consent.
If you believe a minor has provided us with personal data, please email contact@thewhiteproj.com and we will promptly delete it.

IV. Categories of Guest Personal Data and Purposes for Processing

We may collect and process the following categories of data:

Category of DataExamplesPurpose of ProcessingPersonal IdentifiersName, title, date of birthIdentify and communicate with you; manage bookings; comply with lawContact InformationAddress, email, phone numberProvide customer support; send service updates; marketing (with consent if required)Financial DataCredit card details, billing informationProcess transactions; prevent fraudGovernment IDsPassport, visa, national IDComply with travel requirements; verify identityHealth or Accessibility DataDietary needs, medical conditions, vaccination statusProvide safe and personalized travel servicesOnline and Device DataIP address, cookies, usage logsImprove our website; ensure security; analyze preferencesCommunications and FeedbackEmails, messages, surveysRespond to inquiries; improve our services

We collect only what is necessary for legitimate business purposes and retain it only as long as needed.
If we need to use your data for a new purpose, we will inform you and obtain consent where required.

V. Special Categories of Personal Data

During your interactions with us, we may receive information that reveals sensitive details, such as:

  • health conditions,

  • religious beliefs (through dietary requests), or

  • political affiliation (if traveling as part of an organization).

We process such data only when necessary to provide our services, protect vital interests, or with your explicit consent.
You may withdraw consent at any time, though this may affect our ability to provide certain services.

VI. Legal Basis for Processing

We process Guest Personal Data under one or more of the following bases:

  1. Performance of a contract – to deliver the services you request;

  2. Legitimate interests – to operate, improve, and secure our business;

  3. Legal obligation – to meet regulatory or reporting requirements;

  4. Consent – for optional uses such as marketing or special category data.

If we rely on consent, you can withdraw it anytime by emailing contact@thewhiteproj.com.

VII. Disclosures of Guest Personal Data to Third Parties

We do not sell personal data for money and do not share SMS opt-in data.
We may share Guest Personal Data only where necessary:

  • Service providers: to deliver travel, accommodation, transport, or technical support.

  • Business partners: to manage payments, analytics, and marketing (as allowed by law).

  • Authorities: to comply with legal requirements or respond to lawful requests.

  • Professional advisers: such as lawyers or auditors for compliance and governance.

  • Corporate transactions: in the event of a merger, acquisition, or restructuring, subject to confidentiality safeguards.

VIII. International Data Transfers

TWP is based in Hong Kong SAR and may transfer or store Guest Personal Data in other jurisdictions where we or our service providers operate.
Whenever data is transferred outside Hong Kong, we take reasonable steps to ensure an adequate level of protection consistent with this Notice and applicable privacy laws.
We use contractual safeguards (such as data-processing agreements or standard contractual clauses) to ensure that your information is processed securely and lawfully.

IX. Data Security and Retention

TWP maintains appropriate technical and organizational measures to protect Guest Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
While we take these precautions, no system or transmission over the internet is completely secure, and we cannot guarantee absolute protection.

We retain Guest Personal Data for only as long as necessary to fulfil the purposes outlined in this Notice, meet legal obligations, resolve disputes, and enforce agreements.
When data is no longer needed, we delete, anonymize, or securely archive it.
In some cases, we may retain de-identified data for analytics or research without further notice.

X. Your Privacy Rights

Depending on applicable law, you may have some or all of the following rights regarding your personal information:

  1. Access – Request a copy of the personal data we hold about you.

  2. Rectification – Ask us to correct or update inaccurate or incomplete information.

  3. Erasure (“Right to be Forgotten”) – Request deletion of your data where it is no longer needed.

  4. Restriction of Processing – Ask us to limit how we use your data in specific circumstances.

  5. Objection – Object to processing based on legitimate interests, including direct marketing.

  6. Data Portability – Request to receive your data in a structured, commonly used format.

  7. Withdrawal of Consent – Withdraw consent at any time, without affecting prior lawful processing.

To exercise any of these rights, please email contact@thewhiteproj.com.
We will respond without undue delay and within any legally required timeframe.
We may ask for additional information to verify your identity before processing your request.
If you believe we have not handled your data properly, you may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.

XI. CCTV and On-Premise Monitoring

To ensure the safety and security of guests, staff, and property, TWP may operate closed-circuit television (CCTV) in certain facilities, offices, or vehicles.
Recordings are used solely for legitimate business interests, including crime prevention, safety investigations, and compliance with health and safety requirements.
CCTV data is retained only as long as necessary for these purposes, after which it is securely deleted.

XII. Guest Profiles and Personalization

TWP may create a “Guest Profile” to better understand your preferences and tailor our communications and offerings.
Profiles may be based on your booking history, feedback, survey responses, and online interactions.
This helps us offer bespoke travel experiences, targeted promotions, and enhanced service quality.
We do not engage in automated decision-making that produces legal or similarly significant effects without your explicit consent.

XIII. Marketing Communications

We may contact you by email, phone, or SMS to provide updates about our products and services if you have made a booking with us or have opted-in to receive such communications.
You can opt out at any time by:

  • clicking the “Unsubscribe” link in our emails,

  • replying “STOP” to SMS messages, or

  • emailing contact@thewhiteproj.com with “Unsubscribe” in the subject line.

We will continue to send essential transactional or service messages that are not promotional in nature.

XIV. Cookies and Similar Technologies

TWP and our authorized service providers use cookies and related technologies to enhance your online experience and improve our website performance.

1. What Are Cookies?

Cookies are small text files placed on your device when you visit our websites.
They allow us to recognize returning visitors, store preferences, and analyze site usage.
Cookies do not give us access to your device or any information beyond what you choose to share.

2. Types of Cookies We Use

  • Strictly Necessary Cookies – Essential for core site functionality (e.g., booking forms, secure login).

  • Functionality Cookies – Remember your preferences such as language, region, or display settings.

  • Analytics / Performance Cookies – Collect anonymous data about how visitors use our site to help us improve content and usability.

  • Marketing Cookies – Used to deliver relevant advertisements and track effectiveness of campaigns.

3. Managing Cookies

You can control cookies through your browser settings.
Most browsers let you refuse or delete cookies; however, some site features may not work properly without them.
For more information, visit www.allaboutcookies.org.

4. Other Tracking Technologies

We may use:

  • Web Beacons/Pixels to track engagement with our pages or emails;

  • Embedded Scripts to analyze how users interact with our content;

  • Server Logs to monitor site performance and security.

XV. Data Retention Policy

We retain different categories of Guest Personal Data for varying periods depending on purpose and legal requirements.
Generally:

  • Booking and transaction data: 7 years for accounting and taxation.

  • Customer service correspondence: up to 3 years after resolution.

  • Marketing preferences: until you opt out.

  • CCTV footage: typically 30–90 days, unless required for an ongoing investigation.

Once the retention period expires, the data is securely deleted or anonymized.

XVI. Social Media and Third-Party Websites

Our website and marketing materials may contain links to or integrations with third-party websites and social media platforms such as Facebook, Instagram, X (Twitter), YouTube, or others.
Please note that these platforms operate independently from TWP, and we are not responsible for their privacy practices or content.

If you choose to interact with us via social media, any information you post, submit, or share will be subject to that platform’s privacy policy.
We recommend reviewing the privacy notices of any external sites you visit before providing personal information.

XVII. Changes to This Notice

TWP reserves the right to update or modify this Privacy Notice at any time.
When changes are made, we will:

  • update the “Last Updated” date at the top of this page, and

  • post the revised version on our website.

Substantive changes will take effect upon posting unless otherwise stated.
By continuing to use our services after any changes, you acknowledge and accept the updated Notice.

XVIII. Your Consent

By using our website, booking our services, or otherwise providing personal data to TWP, you acknowledge that you have read and understood this Privacy Notice and agree to the collection, use, and disclosure of your information as described herein.

XIX. Questions and Contact Information

If you have any questions, concerns, or complaints regarding this Notice or our data-handling practices, please contact us at:

The White Project Travel Limited
Email: contact@thewhiteproj.com
Attention: Data Protection Officer
Address: [Insert Registered Office Address], Hong Kong SAR

We will respond promptly and in accordance with applicable privacy laws.
If you are dissatisfied with our response, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong for further assistance.

XX. Governing Law and Jurisdiction

This Privacy Notice and any disputes arising in connection with it are governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region.
You agree that the courts of Hong Kong shall have exclusive jurisdiction to resolve any disputes relating to the interpretation, validity, or enforcement of this Notice.

XXI. Summary of Key Points

For your convenience, below is a summary of the key points from this Notice:

  • Who we are: The White Project Travel Limited, a travel company based in Hong Kong SAR.

  • What we collect: Personal details, booking information, financial and health data, preferences, and online behavior data.

  • Why we collect it: To process bookings, personalize experiences, ensure legal compliance, and improve services.

  • How we protect it: By using technical and organizational safeguards aligned with international best practices.

  • Your rights: Access, correction, deletion, restriction, objection, portability, and withdrawal of consent.

  • How to contact us: Email contact@thewhiteproj.com or write to our Data Protection Officer in Hong Kong.

Effective Date

This Privacy Notice is effective as of October 1, 2025 and remains in force until replaced or amended by TWP.