Privacy Policy
Effective date: 10 July 20261. Who this Privacy Policy applies to
This Privacy Policy explains how Dusk Limited, a Hong Kong company (“Dusk”, “we”, “us” or “our”), collects, uses, stores, transfers and protects personal information through www.inkstonechina.com, related forms, waitlists, enquiries, email communications and program-administration activities for the Inkstone brand.
北京甲虫国际旅行社有限公司 (“JiaChong”) is a qualified China travel operator that provides all China-side travel services. Jiachong may collect and process personal information as a program operator or service provider. Where a program agreement or form provides additional privacy terms, those terms also apply.
This Policy applies to website visitors, waitlist subscribers, programme enquirers, applicants, participants, clients, emergency contacts, vendors, partners and other individuals whose personal information is provided to us.
2. Personal information we collect
Depending on how you interact with us, we may collect the following categories of personal information:
Contact and identity information
Name, email address, phone number, nationality, country/region, organisation, role, age confirmation and preferred contact method.
Enquiry and application information
Waitlist responses, programme interests, travel preferences, eligibility information, educational or professional background, messages, survey responses and application answers.
Program administration information
Passport and visa information, travel dates, emergency contacts, insurance details, medical declarations, allergies, dietary restrictions, accessibility needs, rooming preferences and logistics information, where required for a program.
Payment and transaction information
Invoice details, payment status, payment reference, bank transfer status, refunds, reconciliation records and limited payment-provider records. We do not normally receive full bank-account credentials or full card details.
Media and program outputs
Photographs, videos, audio, testimonials, field notes, sketches, interviews and participant outputs where collected under program documents or consent forms.
Technical and usage information
IP address, device/browser information, pages viewed, form interaction, cookies, analytics identifiers, referral source and website performance information.
Communications
Emails, messages, call notes and records of consents, opt-outs, support requests and complaints.
3. How we collect information
Directly from you through the Website; when you contact us, submit a form, join a waitlist, apply for a program, make payment, attend a program, communicate with us by email
from a person acting on your behalf, such as a payer, parent, assistant, institution, organizer or emergency contact;
from JiaChong, vendors, partners, insurers, payment providers or other program-related parties;
automatically through cookies, hosting logs, analytics and similar technologies when you use the Website.
Social media and messaging platforms, including Instagram, WhatsApp and WeChat Official Account, where you interact with us through those channels or where content is published with your consent.
4. Purposes of use
We may use personal information for the following purposes:
operating, maintaining, securing and improving the Website;
responding to enquiries, managing waitlists and sending requested information;
assessing eligibility and suitability for programs;
administering applications, participant agreements, invoices, payment instructions and program communications;
planning and operating programs, including logistics, accommodation, meals, transport, site access, insurance, health and safety, emergency response and participant support;
sharing necessary information with JiaChong, local vendors, guides, facilitators, insurers, medical providers, emergency responders, payment providers and professional advisers;
processing payments, reconciliations, refunds, chargebacks, accounting, audit and tax records;
obtaining and recording consents, waivers, medical declarations, code-of-conduct acknowledgements and media permissions;
marketing Inkstone-branded programs, events and updates where permitted by law and by your consent or indication of no objection;
complying with legal, regulatory, tax, accounting, insurance, safety, security and dispute-resolution obligations;
protecting the rights, safety and property of participants, local communities, Dusk, JiaChong, partners and others.
5. Required and optional information
Some information is required to provide a service, process an enquiry, evaluate an application, confirm a booking, arrange a program, manage safety, process payment, comply with law or respond to an emergency. If you do not provide required information, we may be unable to respond to you, place you on a waitlist, process your application, confirm your booking, operate the program safely or provide the relevant service.
Marketing consent, non-essential media consent and certain optional preferences are voluntary unless expressly stated otherwise. Refusing optional information will not normally prevent participation, although it may limit optional services or communications.
6. Sensitive personal information and medical data
For programs, we may need to collect health, allergy, dietary, medication, mobility, accessibility, insurance, passport, visa, emergency-contact and similar information. Some of this may be sensitive personal information under applicable law. We collect and use it only where necessary for program administration, safety, emergency response, insurance, legal compliance or another stated purpose.
Where required by applicable law, we will obtain separate consent for sensitive personal information and will provide additional notice about why it is necessary and how it may affect your rights and interests.
7. Direct marketing
We may send Inkstone-branded newsletters, alumni updates, event invitations, heritage travel program information and similar cultural or educational offerings only where permitted by law and where you have consented or indicated no objection in the manner required by applicable law. We will not use passport, health, medical, payment, insurance or emergency-contact information for direct marketing.
We may send marketing communications by email, WhatsApp, Instagram, WeChat Official Account or other communication channels where permitted by law and where you have consented or indicated no objection where required. You may opt out at any time by emailing hello@inkstonechina.com or using the unsubscribe, unfollow, blocking or account-management function available on the relevant platform.
We will not sell or provide your personal information to third parties for their own direct marketing or for gain unless separate consent is obtained where required by law.
8. Disclosure and transfer of information
We may disclose or transfer personal information to the following classes of recipients where reasonably necessary for the purposes above:
JiaChong and other qualified China travel operators or program partners;
accommodation providers, transport providers, guides, facilitators, experts, venues, heritage-site partners, community hosts and local vendors;
insurers, insurance brokers, medical providers, emergency responders and assistance providers;
Airwallex, banks, payment providers, accountants, auditors, tax advisers and reconciliation service providers;
website hosting providers, form providers, email platforms, cloud storage providers, analytics providers and IT support providers;
legal advisers, professional advisers, dispute-resolution bodies, regulators, law enforcement and courts where required or permitted by law;
a successor or assignee in connection with a restructuring, merger, transfer or sale of relevant business or assets, subject to appropriate protections.
9. Cross-border transfers
Inkstone-related services may involve Hong Kong, mainland China and other jurisdictions. Personal information may be accessed from, stored in or transferred to Hong Kong, mainland China, your home jurisdiction, and jurisdictions where our service providers, payment providers, cloud services, email platforms, form tools or partners are located.
Where personal information is transferred from mainland China to Dusk in Hong Kong or to another overseas recipient, we and the relevant PRC personal information handler will provide required notices and obtain separate consent or use another legally permitted transfer mechanism where required by the PRC Personal Information Protection Law or other applicable law.
Where personal information is transferred internationally, we use contractual, organisational and technical measures appropriate to the nature of the information and the transfer.
10. Cookies, analytics and similar technologies
The Website may use cookies, pixels, logs, analytics tags and similar technologies to operate the site, remember preferences, measure performance, understand traffic, secure forms and improve content. Some cookies are necessary for the Website to function. Non-essential analytics or marketing cookies will be managed in accordance with applicable law and any cookie banner or settings made available on the Website.
You can manage cookies through your browser settings. Blocking cookies may affect Website functionality.
11. Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including responding to enquiries, managing applications, operating programs, maintaining audit and accounting records, complying with legal and tax obligations, handling insurance and incident records, resolving disputes and protecting legal rights.
Indicative retention periods may include: website enquiry and waitlist records for up to 3 years after last interaction; unsuccessful application records for up to 2 years unless you consent to longer contact; program participant records for up to 7 years after program completion or longer where required for legal, tax, insurance or dispute purposes; incident, medical emergency or legal records for as long as reasonably necessary for claims or statutory limitation periods. Actual retention may vary depending on law and the nature of the record.
12. Security
We use reasonable administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure. No website, email system, cloud service or internet transmission is completely secure. You should avoid sending highly sensitive information by unsecured email unless requested and appropriate.
13. Your rights
Subject to applicable law, you may have rights to access, correct, delete, restrict, object to or receive a copy of personal information, withdraw consent, opt out of marketing, or complain to a data-protection authority. Under Hong Kong’s Personal Data (Privacy) Ordinance, you have rights to request access to and correction of personal data held by a data user.
To exercise privacy rights, contact hello@inkstonechina.com. We may need to verify your identity before responding. We may charge a reasonable fee for data access requests where permitted by law.
14. Emergency contacts and third-party information
If you provide personal information about another person, including an emergency contact, payer, companion, referee or representative, you confirm that you have authority to provide it and that you have informed that person of this Policy and the relevant use, disclosure and transfer of their information.
15. Children and age limits
The Website and Inkstone programs are not directed to children under 18 unless a specific program states otherwise and appropriate guardian consent procedures are implemented. We do not knowingly collect personal information from children under 18 through the Website for program participation without appropriate consent and legal review.
16. Third-party websites and services
The Website may link to third-party websites, forms, payment providers, social media, maps or partner resources. Those third parties have their own privacy notices and practices. We are not responsible for third-party privacy practices except where we engage a service provider to process information on our behalf.
17. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be posted on the Website with a revised effective date. Material changes may also be communicated by email or other reasonable means where appropriate.
18. Contact
For privacy questions, access or correction requests, withdrawal of consent, marketing opt-outs or complaints, contact:
Dusk Limited / Inkstone Privacy Contact
Email: hello@inkstonechina.com