GENERAL POLICY

1. Data Collection

Grand Pioneers collects personal information only when guests voluntarily use our services, including booking cabins or tours, subscribing to newsletters, participating in surveys, submitting feedback, or contacting customer support.

Personal data may include full name, date of birth, nationality, contact details, passport information (when required for cruise operations, port clearance, or other competent authority requirements), payment and billing details, and information of accompanying travelers.

Guests are not required to provide personal information unless such information is necessary to deliver requested services or to comply with applicable laws and regulations.

2. Purpose of Data Processing

Personal information is processed solely for legitimate, specific, and necessary purposes, including but not limited to:

• Confirming and managing bookings
• Processing payments and financial transactions
• Coordinating cruise operations and passenger manifests
• Communicating itinerary changes due to weather conditions or authority requirements
• Providing customer support and handling complaints
• Preventing fraud and ensuring transaction security
• Fulfilling legal, accounting, and regulatory obligations
• Improving service quality and customer experience

Participation in surveys is voluntary, and responses are generally collected in anonymous or aggregated form unless otherwise explicitly stated.

3. Legal Basis for Data Processing

Personal data is processed based on one or more of the following legal grounds:

• The guest’s consent when using services that require personal data
• The necessity to perform contracts or service agreements with guests
• Compliance with legal obligations under Vietnamese law, including maritime, port authority, immigration, tax, safety, and security regulations

In cases where personal data is required to fulfill legal obligations or comply with requests from competent authorities, such data may be processed without separate consent, in accordance with applicable laws.

4. Automatic Data Collection & Cookies

We may automatically collect technical data such as IP address, device type, operating system, browser information, cookies, and website activity to analyze usage trends, enhance system security, diagnose technical issues, and improve user experience.

Guests may disable cookies through browser settings; however, doing so may limit certain website features or booking functions.

5. Data Sharing with Third Parties

Personal information is shared strictly on a need-to-know basis with cruise operators, service partners, payment processors, internal departments, and competent authorities when required by law.

Grand Pioneers does not sell, rent, or trade personal information.

6. Data Protection Measures

Grand Pioneers applies appropriate administrative, technical, and physical safeguards, including encryption, access control, firewalls, and system monitoring. However, absolute security cannot be guaranteed.

7. Rights of Data Subjects

Guests have the right to access, correct, update, request deletion or restriction of processing, withdraw consent, and submit privacy-related inquiries or complaints.

Guests also have the right to file complaints, initiate legal proceedings, or request protection of their lawful rights in accordance with Vietnamese law.

8. Data Controller Information

VIET THUAN TRANSPORT CO., LTD
(Operator of Grand Pioneers Cruises)

Address: 412 Quang Trung, Uong Bi, Quang Ninh, Vietnam
Email: info@grandpioneers.com

All privacy-related requests should be directed to the above contact details.

9. Policy Updates

This privacy policy may be updated from time to time and shall take effect from the date of publication on the official website.