Privacy Policy

1. Information We Collect & Strict Data Isolation

We collect both standard and sensitive personal information strictly necessary to deliver our high-altitude, restricted-zone expedition logistics:

• General Personal Data (Web Inquiries): Full legal name, nationality, email address, phone number, and expedition preferences.
• Sensitive Special Category Data (Collected Offline / Encrypted Portals Only):
• Identity & Travel Documents: High-resolution passport scans, Chinese visa page scans, and port-of-entry details required for Tibet Travel Permits (TTP), military border passes, and Foreign Affairs Office clearances.
• Health & Medical Declarations: Pre-departure medical forms, high-altitude acclimatization profiles, blood pressure records, and emergency contact details used for AMS (Acute Mountain Sickness) suitability assessment.

2. Third-Party Data Processors & Form Infrastructure Disclosure

To receive web inquiries and protect site infrastructure, CAE engages trusted third-party Data Processors bound by strict Data Processing Agreements (DPAs):

3. Cross-Border Data Pipeline & Legal Safeguards (GDPR / PIPL)

To secure mandatory permits (TTP, border passes) and coordinate high-altitude emergency medical rescue, non-sensitive inquiry data and offline-collected permit credentials flow through the following pipeline:

1. Client Submission: Web inquiry sent via Web3Forms API (SSL/TLS 256-bit encrypted).
2. CAE Secure Relay: Delivered directly to CAE's encrypted operational inbox ([email protected]).
3. Chengdu HQ & Authorities: Processed by CAE Operational HQ in Chengdu, P.R.C., and submitted to relevant municipal, provincial, and military border defense authorities.

• Legal Grounds (GDPR Art. 6 & Art. 9): Processed under Contract Performance (Art. 6(1)(b)), Explicit Consent for Special Category Health Data (Art. 9(2)(a)), and Statutory Compliance (Art. 6(1)(c)).
• International Transfer Safeguards: International transfers of EU/UK data are governed by Standard Contractual Clauses (SCCs) and DPA agreements.

4. Strict Data Retention & Destruction Schedule

CAE enforces rigid, non-negotiable retention limits across all data categories:

• Website Vetting Inquiries: General inquiries that do not result in a confirmed booking are permanently purged within 180 days.
• Passport & Visa Permit Scans: Digital copies of passport scans and visa credentials submitted for TTP/border pass clearance are permanently shredded and deleted within 30 days following expedition completion.
• Medical & Altitude Health Declarations: Pre-departure medical forms and emergency health profiles are retained for 90 days post-expedition for medical follow-up and insurance verification, after which they are securely destroyed.
• Tax & Accounting Logs: Financial invoices and transaction logs are retained for 7 years to satisfy statutory tax laws.

5. Data Subject Access Requests (DSAR) & User Rights

Under GDPR, UK-GDPR, and PIPL, you possess statutory rights regarding your personal data:

• Right of Access & Rectification: Request copies of your data or correct inaccurate information.
• Right to Erasure ("Right to be Forgotten"): Request permanent deletion of your personal data (subject to statutory tax retention laws).
• Right to Restrict / Object: Object to specific processing activities or withdraw consent at any time.

To submit a Data Subject Access Request (DSAR), contact our Data Compliance Desk at: [email protected]. CAE acknowledges DSAR requests within 72 hours and fulfills them within 30 days free of charge.

6. Security Incident Response & 72-Hour Breach Notification

CAE maintains an active Incident Response Protocol (IRP). In the event of a confirmed security incident or data breach affecting personal identifiers:

• Containment: Compromised systems are immediately isolated within 1 hour.
• 72-Hour Notification: In accordance with GDPR Art. 33/34, CAE will notify relevant Supervisory Authorities (e.g. EU DPAs / UK ICO) and impacted clients within 72 hours of breach confirmation, detailing the nature of the event and remediation measures.

7. US State Privacy Disclosures (CCPA / CPRA Compliance)

California residents have the right to request disclosure or deletion of personal data collected. CAE does not sell, rent, lease, or share personal or health data with third parties or data brokers. Contact: [email protected].