This Privacy Policy explains how China Unlocked, doing business as Seeo ("Seeo," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information when you access or use the Seeo website, applications, services, features, and related technology (collectively, the "Seeo Platform").
It also describes certain privacy rights and choices that may be available to you.
Please read this Privacy Policy carefully.
By using the Seeo Platform, you acknowledge that you have reviewed this Privacy Policy.
Where applicable law requires consent for a particular activity, including certain uses of sensitive personal information, marketing technologies, precise location information, or international transfers, Seeo will request that consent separately where required.
This Privacy Policy should be read together with our Terms of Service, Cookie Policy, and other privacy notices that may be presented when you use a particular feature.
1. Who We Are
The Seeo Platform is operated by:
China Unlocked Doing business as Seeo
For purposes of applicable privacy laws, Seeo may act as a "controller," "business," "personal information processor," or similar responsible entity with respect to personal information processed for Seeo's own purposes.
Privacy inquiries may be directed to:
support@seeotravel.com
Where applicable law requires a regional representative, data protection officer, or other privacy contact, additional information will be provided in this Privacy Policy or an applicable supplemental notice.
2. Scope of This Privacy Policy
This Privacy Policy applies when you:
- visit or browse the Seeo Platform;
- create or maintain a Seeo account;
- search for Experiences;
- make, modify, or cancel a Booking;
- participate in an Experience;
- communicate with a Host;
- communicate with Seeo;
- contact customer support;
- submit reviews, ratings, photographs, or other Content;
- participate in surveys or promotions;
- use location-based or personalized features;
- interact with Seeo marketing communications; or
- otherwise interact with the Seeo Platform.
This Privacy Policy applies primarily to personal information processed by Seeo.
Independent Hosts, payment providers, identity-verification providers, social-login providers, and other third parties may process personal information under their own privacy obligations and policies.
3. Our Role and the Role of Hosts
Seeo operates an online marketplace connecting Travelers with independent Hosts who provide Experiences.
When you make a Booking, Seeo may provide the applicable Host with personal information reasonably necessary to:
- manage the Booking;
- identify Participants;
- communicate with you;
- provide the Experience;
- satisfy participation requirements;
- respond to special requests;
- address safety concerns; or
- comply with applicable law.
Hosts are independent service providers.
Depending on the circumstances and applicable law, a Host may act as an independent controller, business, personal information processor, or other independently responsible entity with respect to personal information the Host receives or collects for its own purposes.
This means a Host may have privacy obligations separate from Seeo.
Seeo does not control every independent use of personal information by a Host outside the Seeo Platform.
Hosts are required to handle Traveler information in accordance with applicable law and relevant Seeo policies.
If you have questions about how a Host independently handles your information, you may contact that Host directly.
4. Categories of Personal Information We May Collect
Depending on how you use Seeo, we may collect or process categories of personal information including:
Identifiers
Such as:
- name;
- email address;
- telephone number;
- account identifier;
- username;
- authentication information;
- IP address; and
- other identifiers.
Account and Profile Information
Such as:
- profile photograph;
- preferred language;
- country or region;
- account settings;
- saved Experiences;
- preferences; and
- notification settings.
Booking and Transaction Information
Such as:
- Experiences searched or booked;
- Booking dates;
- Booking status;
- Participant count;
- itinerary details;
- meeting or pickup information;
- cancellation history;
- refunds;
- amounts paid; and
- transaction history.
Payment-Related Information
Such as:
- billing information;
- payment method type;
- payment status;
- transaction identifiers;
- limited payment-card information provided by payment processors; and
- fraud or risk indicators.
Seeo may not receive or store full payment-card credentials where those credentials are processed directly by an independent payment provider.
Communications
Such as:
- messages between Travelers and Hosts;
- communications with customer support;
- complaints;
- dispute information;
- survey responses; and
- other communications submitted through the Platform.
User Content
Such as:
- reviews;
- ratings;
- photographs;
- videos;
- profile Content;
- comments; and
- feedback.
Device and Usage Information
Such as:
- IP address;
- browser type;
- operating system;
- device type;
- device identifiers;
- pages viewed;
- searches;
- clicks;
- session activity;
- referring pages;
- login information;
- approximate geographic location derived from IP address;
- crash information; and
- technical logs.
Inferences
We may generate inferences based on information such as:
- searches;
- saved Experiences;
- Booking history;
- location;
- preferences; and
- Platform interactions
to help personalize the Seeo Platform or improve recommendations.
Other Information
Where necessary for a particular Experience or service, we may process additional information described at or before the point of collection.
5. Information You Provide Directly
Account Information
When you create or maintain a Seeo account, we may collect information such as:
- name;
- email address;
- telephone number;
- authentication credentials;
- profile photograph;
- preferred language;
- country or region; and
- account preferences.
Passwords may be stored only in protected or hashed form or processed by an authentication provider, depending on Seeo's technical infrastructure.
Booking Information
When you make or manage a Booking, we may collect information such as:
- Experience selected;
- Booking date and time;
- Participant information;
- contact information;
- meeting or pickup information;
- special requests;
- accessibility requests; and
- other information reasonably necessary to facilitate the Booking.
The information required will vary by Experience.
Traveler Documentation
Certain Experiences or legally required processes may require additional information.
Depending on the Experience, this may include:
- legal name;
- nationality;
- date of birth;
- identification information;
- passport information;
- driver's license information;
- permits;
- emergency contact information; or
- other travel-related documentation.
Seeo does not require all Travelers to provide all of these categories of information.
We seek to collect such information only where reasonably necessary for a specific Booking, verification process, legal requirement, safety purpose, or service.
Health, Accessibility, and Dietary Information
Certain Experiences may require or benefit from limited information concerning:
- allergies;
- dietary restrictions;
- mobility or accessibility requirements;
- relevant health conditions; or
- other information affecting safe participation.
Seeo does not seek to collect health information unless reasonably necessary for the relevant purpose.
Where applicable law treats such information as sensitive and requires separate consent, Seeo will seek that consent where required.
Identity Verification
Where identity or eligibility verification is required, Seeo or a verification provider may process information including:
- full legal name;
- date of birth;
- government-issued identification;
- identification document images;
- verification status;
- identity-verification results; and
- fraud or security indicators.
Where practical, Seeo may retain verification results rather than complete identification documents.
6. Information Collected Automatically
When you access or use the Seeo Platform, certain information may be collected automatically.
This may include:
- IP address;
- browser type;
- operating system;
- device information;
- device identifiers;
- language preferences;
- approximate geographic location;
- dates and times of access;
- pages viewed;
- searches;
- clicks;
- interaction history;
- referring URLs;
- session identifiers;
- login events;
- crash reports;
- security events; and
- other technical information.
We may use this information to:
- operate the Platform;
- authenticate Users;
- maintain security;
- prevent fraud;
- troubleshoot problems;
- understand Platform usage;
- improve functionality; and
- personalize certain features.
7. Information We Receive from Third Parties
We may receive personal information from third parties.
These may include:
Social Login Providers
If you use a service such as Google or Apple to sign in, we may receive information you authorize the provider to disclose, such as:
- name;
- email address;
- profile information; and
- authentication identifiers.
Payment Providers
Payment providers may provide information such as:
- payment status;
- transaction identifiers;
- billing information;
- payment method type;
- limited card information;
- chargeback information; and
- fraud indicators.
Identity Verification Providers
Verification providers may provide:
- identity verification results;
- document verification status;
- age verification;
- fraud indicators; and
- security information.
Hosts
Hosts may provide information relating to:
- participation;
- attendance;
- no-shows;
- cancellations;
- communications;
- incidents;
- disputes;
- safety concerns; or
- customer-service issues.
Analytics, Advertising, and Technology Providers
Where used and permitted by law, we may receive information from analytics, advertising, attribution, fraud-prevention, security, and technology providers.
Other Users
Another Traveler may provide information about you when making a Booking on your behalf or including you as a Participant.
8. Sensitive Personal Information
Some information processed through Seeo may be considered "sensitive personal information," "special category data," or a similar category under applicable law.
Depending on the circumstances, this may include:
- government identification information;
- financial account information;
- precise geolocation;
- health information;
- biometric information used for verification;
- information concerning minors; or
- other legally protected information.
Seeo seeks to process sensitive personal information only where there is a specific and legitimate purpose and where the information is reasonably necessary for that purpose.
We may use enhanced safeguards, limited access, shorter retention practices, or specialized providers for certain sensitive information.
Where applicable law requires separate, explicit, or additional consent, Seeo will seek that consent through a separate mechanism where required.
General acceptance of this Privacy Policy does not automatically constitute consent for processing that legally requires separate consent.
9. Information About Other Travelers
If you provide personal information about another person, including another Participant in a Booking, you represent that you are authorized to provide that information or otherwise have a lawful basis to do so.
You should provide only information reasonably necessary for the Booking.
You are responsible for informing other Participants about material Booking information and, where appropriate, directing them to this Privacy Policy.
Certain information may require consent directly from the Participant.
Seeo may request separate consent where required by applicable law.
10. How We Use Personal Information
Seeo may use personal information for the purposes described below.
Provide and Operate the Seeo Platform
We may use information to:
- create and maintain accounts;
- authenticate Users;
- display Platform Content;
- process searches;
- save preferences;
- facilitate Bookings;
- manage reservations;
- provide Booking confirmations;
- provide account functionality; and
- otherwise provide requested services.
Facilitate Experiences
We may use information to:
- connect Travelers with Hosts;
- provide Hosts with necessary Booking information;
- communicate meeting instructions;
- support participation requirements;
- manage Booking changes;
- process cancellations; and
- facilitate refunds.
Process Payments
We may process information to:
- facilitate payments;
- verify transactions;
- process refunds;
- address chargebacks;
- prevent unauthorized payments; and
- maintain transaction records.
Provide Customer Support
We may use information to:
- respond to inquiries;
- investigate complaints;
- resolve Booking issues;
- facilitate Traveler--Host disputes;
- communicate with Users; and
- provide technical assistance.
Safety, Security, and Fraud Prevention
We may use information to:
- authenticate Users;
- prevent account compromise;
- detect fraud;
- identify suspicious transactions;
- investigate abuse;
- enforce Platform policies;
- investigate safety incidents; and
- protect Seeo, Travelers, Hosts, and others.
Personalization and Recommendations
We may use information to:
- personalize search results;
- recommend Experiences;
- remember preferences;
- rank Content;
- improve relevance; and
- customize portions of the Platform.
Improve and Develop Seeo
We may use information to:
- analyze Platform performance;
- troubleshoot;
- conduct research;
- develop new functionality;
- measure usage;
- improve user experience; and
- maintain Platform quality.
Communications
We may use information to send:
- Booking confirmations;
- reminders;
- account communications;
- security notices;
- service updates;
- customer-support communications;
- policy notices; and
- legal notices.
Marketing
Where permitted by applicable law, Seeo may use information to provide:
- promotional emails;
- Experience recommendations;
- Seeo news;
- offers; and
- marketing communications.
Where consent is required, marketing will be based on the appropriate consent or choice.
Legal and Compliance Purposes
We may use information to:
- comply with applicable laws;
- respond to lawful requests;
- maintain legally required records;
- investigate fraud or misconduct;
- enforce agreements;
- establish, exercise, or defend legal claims; and
- protect legal rights.
11. Legal Bases for Processing
Where applicable law requires Seeo to identify a legal basis for processing, we may rely on one or more of the following.
Performance of a Contract
We may process information where necessary to:
- create or administer your account;
- process a Booking;
- facilitate payments;
- communicate with Hosts;
- provide requested services; or
- perform obligations under our Terms.
Legitimate Interests
Where permitted by law, Seeo may process information where reasonably necessary for legitimate interests such as:
- operating and improving the Platform;
- customer support;
- fraud prevention;
- cybersecurity;
- Platform integrity;
- analytics;
- enforcing policies;
- protecting legal rights; and
- improving recommendations.
Where required, Seeo will consider the impact on your rights before relying on legitimate interests.
Consent
We may rely on your consent for processing such as:
- certain marketing activities;
- optional cookies;
- certain advertising technologies;
- precise location;
- certain sensitive information;
- certain international transfers; or
- other activities where consent is legally required.
Where processing relies on consent, you may withdraw consent subject to applicable law.
Withdrawal does not affect processing that was lawful before withdrawal.
Legal Obligations
We may process information where necessary to comply with:
- laws;
- regulations;
- court orders;
- lawful government requests;
- tax requirements;
- accounting obligations; or
- other legal obligations.
Vital Interests and Other Legal Bases
Where permitted by applicable law, we may process information to protect a person's vital interests or on another legally recognized basis.
12. How We Disclose Personal Information
Seeo may disclose personal information to the categories of recipients described below.
We seek to disclose only information reasonably necessary for the relevant purpose.
These disclosures may include:
- Hosts and Suppliers;
- payment providers;
- identity-verification providers;
- authentication providers;
- cloud and technology providers;
- customer-support providers;
- communications providers;
- fraud-prevention providers;
- security providers;
- analytics providers;
- advertising providers where applicable;
- professional advisers;
- affiliates;
- government authorities where legally required;
- counterparties in a corporate transaction; and
- other parties with your direction or consent.
14. Service Providers and Business Partners
Seeo may engage third parties to provide services on our behalf or support Platform operations.
Such providers may include companies providing:
- cloud hosting;
- databases;
- content delivery;
- authentication;
- payment processing;
- customer support;
- email;
- SMS;
- communications;
- identity verification;
- fraud prevention;
- cybersecurity;
- analytics;
- mapping;
- translation;
- document processing; and
- other technical or professional services.
These providers may process personal information as reasonably necessary to perform their services.
Where required by applicable law, Seeo uses contractual, technical, organizational, or other appropriate measures concerning service-provider access to personal information.
15. Payments and Fraud Prevention
Payment information may be processed by independent payment providers.
Depending on the payment arrangement, Seeo may not receive or store complete payment credentials.
Payment providers may process information under their own privacy policies and legal obligations.
Seeo and its providers may use payment-related information to:
- authorize transactions;
- process payments;
- issue refunds;
- investigate chargebacks;
- detect fraud;
- prevent abuse;
- satisfy financial compliance requirements; and
- maintain transaction records.
Payment and fraud-prevention systems may use automated risk indicators or other security tools.
17. Advertising and Analytics
Seeo may use analytics tools to understand how Users interact with the Platform.
These tools may collect information including:
- device information;
- IP address;
- browsing activity;
- Platform interactions;
- referral information; and
- advertising attribution information.
Seeo may also use advertising or marketing technologies in the future.
Where advertising activities require consent, opt-out rights, or other disclosures under applicable law, Seeo will provide the applicable controls.
Seeo does not guarantee that every third-party advertising or analytics provider uses identical definitions or privacy practices.
18. Sale, Sharing, and Targeted Advertising
Seeo does not sell personal information for monetary consideration.
Certain U.S. privacy laws use terms such as "sale," "sharing," or "targeted advertising" more broadly than ordinary commercial use of the word "sell."
For example, certain transfers of identifiers or online activity to advertising or analytics providers may fall within these legal definitions even where no money is paid for personal information.
If Seeo engages in processing that constitutes:
- a sale of personal information;
- sharing of personal information for cross-context behavioral advertising; or
- targeted advertising
under applicable law, Seeo will provide legally required notices and opt-out mechanisms.
Where required, these choices may be provided through a link such as:
Your Privacy Choices
or another legally appropriate mechanism.
Where required by law, Seeo will also recognize applicable browser-based or device-based opt-out preference signals, such as a legally recognized Global Privacy Control signal.
19. International Data Transfers
Seeo is designed to connect international Travelers with Hosts, including Hosts located in China.
As a result, personal information may be processed in countries other than the country where you live.
For example:
- Booking information may be disclosed to a Host in China;
- Seeo may use technology providers located in the United States or other countries;
- customer support may involve personnel or providers in different jurisdictions; and
- payment, authentication, or security providers may process information internationally.
Privacy and data-protection laws vary between countries.
Where applicable law requires safeguards for an international transfer, Seeo may use measures such as:
- contractual protections;
- approved standard contractual clauses;
- legally recognized transfer mechanisms;
- data-transfer assessments;
- security safeguards;
- data minimization;
- localization where required; or
- separate consent where legally required.
The appropriate mechanism may vary depending on:
- the countries involved;
- the type of information;
- the purpose of processing;
- the recipient; and
- applicable law.
Seeo does not represent that one specific transfer mechanism applies to every international transfer.
20. Data Relating to China
Because Seeo facilitates Experiences in China, certain Booking information may need to be disclosed to Hosts, Suppliers, or service providers located in China.
Depending on applicable law, information may also be transferred from China to service providers or Seeo entities located outside China.
Where Chinese privacy and data-protection law applies, Seeo will seek to comply with applicable requirements concerning:
- transparency;
- lawful processing;
- data minimization;
- sensitive personal information;
- security measures;
- data-subject rights; and
- international data transfers.
Where applicable law requires a separate consent for a particular transfer or other processing activity, Seeo will seek such consent separately rather than relying solely on acceptance of this Privacy Policy.
Where required, Seeo may provide additional information concerning:
- the identity or category of an overseas recipient;
- processing purposes;
- categories of personal information transferred;
- methods of processing;
- methods for exercising applicable rights; and
- additional information required by law.
21. Data Retention
Seeo retains personal information for no longer than reasonably necessary for the purposes for which the information is processed, subject to applicable legal and business requirements.
Retention periods may vary based on factors including:
- the nature of the information;
- the purpose for which it was collected;
- whether your account remains active;
- whether a Booking is ongoing or completed;
- fraud or safety concerns;
- dispute history;
- tax or accounting obligations;
- regulatory requirements;
- legal claims; and
- applicable statutes of limitation.
For example:
Account Information
May generally be retained while your account remains active and for an appropriate period afterward where necessary for legitimate legal, security, fraud-prevention, or operational purposes.
Booking and Transaction Records
May be retained as needed for:
- accounting;
- taxation;
- payment processing;
- refunds;
- disputes;
- fraud prevention;
- consumer claims; and
- legal requirements.
Communications
May be retained for periods reasonably necessary for:
- customer support;
- disputes;
- Trust & Safety;
- fraud prevention;
- enforcement; and
- legal obligations.
Identity Information
Where identity verification is required, Seeo seeks to avoid retaining full identification documents longer than reasonably necessary.
Where practical, we may retain confirmation or verification status instead of complete document copies.
Marketing Information
May be retained while you remain subscribed or where otherwise permitted by law.
Seeo may retain limited suppression information after an unsubscribe request so that we can respect your marketing preference.
Security Information
Security logs and fraud-prevention information may be retained for periods reasonably necessary to maintain Platform security and protect against abuse.
Seeo may retain information for longer where required or permitted by applicable law.
22. Data Security
Seeo uses administrative, technical, and organizational measures designed to protect personal information against:
- unauthorized access;
- unauthorized disclosure;
- unlawful processing;
- accidental loss;
- destruction;
- alteration; and
- misuse.
Depending on the circumstances, measures may include:
- encryption;
- access controls;
- authentication;
- secure communications;
- logging and monitoring;
- secure infrastructure;
- data minimization;
- vendor controls; and
- security reviews.
However, no Internet service, electronic transmission, or information-storage system can be guaranteed to be completely secure.
Accordingly, Seeo cannot guarantee that unauthorized third parties will never defeat security measures or improperly access information.
Where required by applicable law, Seeo will provide legally required notifications concerning qualifying personal-information security incidents.
23. Your Privacy Rights
Depending on where you live and which laws apply, you may have rights concerning personal information processed by Seeo.
These may include the right to:
- know whether Seeo processes your personal information;
- access personal information;
- obtain a copy of personal information;
- correct inaccurate personal information;
- delete personal information;
- restrict certain processing;
- object to certain processing;
- withdraw consent;
- receive certain information in portable form;
- opt out of certain advertising activities;
- opt out of sale or sharing where applicable;
- limit certain uses of sensitive information;
- object to certain automated processing;
- appeal certain privacy-request decisions; and
- lodge a complaint with an applicable authority.
Privacy rights are not absolute.
Seeo may decline or limit a request where permitted or required by law, including where information must be retained for:
- legal obligations;
- security;
- fraud prevention;
- completed transactions;
- legal claims;
- public-interest purposes; or
- other legally recognized exceptions.
Seeo may request information reasonably necessary to verify your identity before completing a privacy request.
24. United States Privacy Rights
Residents of certain U.S. states may have additional rights under applicable state privacy laws.
Depending on the jurisdiction and whether the relevant law applies to Seeo, these rights may include:
- right to know;
- right to access;
- right to correct;
- right to delete;
- right to obtain portable data;
- right to opt out of sale;
- right to opt out of sharing;
- right to opt out of targeted advertising;
- right to limit certain uses of sensitive personal information;
- right to opt out of certain profiling or automated decision-making activities;
- right to appeal a privacy-request decision; and
- right not to receive unlawful discriminatory treatment for exercising privacy rights.
Requests may be submitted through:
support@seeotravel.com
Where permitted, an authorized agent may submit certain requests on your behalf.
Seeo may require:
- verification of your identity;
- verification of the agent's authority; or
- direct confirmation from you
before fulfilling an agent request.
25. California Privacy Notice
This Section provides additional information for California residents where the California Consumer Privacy Act, as amended ("CCPA"), applies.
Categories of Personal Information
During the preceding 12 months, depending on the services used, Seeo may have collected categories including:
- identifiers;
- customer-record information;
- commercial information;
- internet or electronic-network activity;
- approximate geolocation;
- payment-related information;
- communications;
- User Content;
- inferences; and
- sensitive personal information where necessary for a particular service.
The specific categories collected from an individual depend on how that person uses Seeo.
Sources
Personal information may come from:
- you;
- other Travelers;
- Hosts;
- payment providers;
- social-login providers;
- identity-verification providers;
- technology providers;
- analytics providers; and
- Platform activity.
Business and Commercial Purposes
Seeo may collect and use personal information for purposes including:
- operating accounts;
- facilitating Bookings;
- providing Experiences;
- processing payments;
- customer support;
- fraud prevention;
- Platform security;
- personalization;
- analytics;
- legal compliance; and
- marketing where permitted.
Disclosure
Seeo may disclose information to categories of recipients described elsewhere in this Privacy Policy, including:
- Hosts;
- service providers;
- payment providers;
- technology providers;
- professional advisers;
- affiliates; and
- government authorities where legally required.
Sale and Sharing
Seeo does not sell personal information for monetary consideration.
If Seeo's advertising or analytics practices constitute "selling" or "sharing" under the CCPA, Seeo will provide the applicable right to opt out.
Sensitive Personal Information
Where Seeo processes sensitive personal information, we generally seek to use it for purposes reasonably necessary to provide requested services, maintain security, prevent fraud, or comply with law.
Where California law provides a right to limit particular uses or disclosures, Seeo will provide that right where applicable.
Retention
Retention is determined using the criteria described in Section 21 --- Data Retention.
California Rights
Where applicable, California residents may have rights to:
- know;
- access;
- correct;
- delete;
- obtain information concerning categories of disclosure;
- opt out of sale or sharing;
- limit certain uses of sensitive personal information; and
- receive non-discriminatory treatment for exercising CCPA rights.
Notice at Collection
Seeo may provide additional notices at or before the point where particular information is collected, especially where required for:
- account registration;
- identity verification;
- sensitive information;
- location information;
- payment information;
- advertising technologies; or
- other feature-specific information collection.
Such notices may link to this Privacy Policy.
26. EEA, United Kingdom, and Switzerland
Where the GDPR, UK GDPR, Swiss data-protection law, or similar laws apply, Seeo may act as a controller of personal information described in this Privacy Policy.
Depending on applicable law, individuals may have rights including:
- access;
- correction;
- erasure;
- restriction;
- objection;
- portability;
- withdrawal of consent; and
- complaint to a supervisory authority.
Where Seeo relies on legitimate interests, you may have a right to object to processing in certain circumstances.
Where Seeo relies on consent, you may withdraw that consent.
For direct marketing based on legitimate interests, applicable objection rights will be respected.
Where legally required, Seeo will identify an applicable:
EEA Representative: UK Representative: Data Protection Officer:
You may also have the right to lodge a complaint with the data-protection authority in the country where you reside, work, or believe a violation occurred.
27. Users in China
Where the Personal Information Protection Law of the People's Republic of China ("PIPL") or other applicable Chinese privacy laws apply, Seeo will process personal information in accordance with applicable legal requirements.
Depending on the circumstances, applicable rights may include rights to:
- receive information and explanations concerning processing;
- access personal information;
- obtain copies;
- correct or supplement inaccurate information;
- delete information;
- withdraw consent;
- restrict or refuse certain processing; and
- cancel an account.
Where Seeo processes sensitive personal information, we will seek to do so only for a specific purpose and where reasonably necessary, subject to applicable legal requirements.
Where separate consent is required by law, Seeo will provide a separate consent mechanism.
Where legally required in connection with an international transfer, Seeo may provide additional information concerning the overseas recipient and transfer and obtain any legally required separate consent.
Withdrawal of consent does not affect processing lawfully conducted before withdrawal.
28. Children and Minors
Seeo Traveler accounts are intended for individuals who are at least 18 years old.
Individuals under 18 are not permitted to independently create Traveler accounts unless Seeo expressly introduces a legally compliant service that permits otherwise.
Adults may make permitted Bookings that include minors.
In connection with such Bookings, Seeo may process limited information concerning a minor where reasonably necessary to:
- identify Participants;
- determine eligibility;
- facilitate an Experience;
- address safety or accessibility needs; or
- comply with applicable law.
Where applicable law requires consent from a parent, guardian, or other authorized person, the required consent must be obtained.
We seek to avoid collecting information about minors that is not reasonably necessary for the relevant service.
Where Chinese law applies, personal information concerning children under 14 may be treated as sensitive personal information and handled accordingly.
If you believe Seeo has improperly collected personal information from a minor, contact:
support@seeotravel.com
29. Marketing Communications
Seeo may offer you the choice to receive promotional communications concerning:
- destinations;
- Experiences;
- offers;
- Platform updates;
- travel inspiration; and
- other Seeo services.
Where required by applicable law, marketing communications will be based on your consent or another legally permitted basis.
Marketing consent is separate from acceptance of the Seeo Terms of Service and is not required merely to create a Traveler account where separate consent is legally required.
You may opt out of promotional email through:
- the unsubscribe link in the email;
- available account settings; or
- other opt-out methods Seeo provides.
Even after opting out of marketing, Seeo may continue to send non-promotional communications concerning:
- your account;
- Bookings;
- transactions;
- security;
- customer support;
- safety; and
- legal notices.
30. Automated Processing and Recommendations
Seeo may use automated systems or algorithms to assist with functions such as:
- ranking search results;
- recommending Experiences;
- detecting fraud;
- identifying suspicious activity;
- protecting account security;
- personalizing Platform Content; and
- improving Platform performance.
These systems may use information including:
- searches;
- Booking activity;
- location;
- device information;
- Platform interactions;
- fraud indicators; and
- preferences.
Seeo may modify automated systems from time to time as Platform technology evolves.
Where applicable law grants rights concerning automated decision-making, profiling, or similar processing that produces legal or similarly significant effects, Seeo will provide applicable notices, choices, or rights where required.
31. Account Deletion
You may request deletion of your Seeo account through available account settings or by contacting:
support@seeotravel.com
Account deletion does not necessarily result in immediate deletion of all personal information.
Seeo may retain information where reasonably necessary or legally required for purposes such as:
- completed Bookings;
- payment records;
- tax or accounting obligations;
- fraud prevention;
- Trust & Safety;
- chargebacks;
- disputes;
- legal claims;
- regulatory requirements;
- preventing repeat abuse; and
- enforcing Seeo agreements.
Seeo may also retain information in backup systems for a limited period as part of normal technical processes.
Where information no longer needs to identify you, Seeo may anonymize or de-identify it where permitted by law.
32. Third-Party Websites and Services
The Seeo Platform may contain links to, or integrations with, third-party:
- websites;
- applications;
- payment services;
- maps;
- social networks;
- identity providers;
- transportation services; or
- other products.
Seeo does not control the independent privacy practices of third parties.
Their collection and processing of personal information may be governed by their own privacy notices and terms.
This Privacy Policy does not apply to independent third-party processing that Seeo does not control.
You should review applicable third-party privacy policies before providing information directly to those services.
33. Business Transfers
Seeo may disclose or transfer personal information in connection with an actual or proposed:
- financing;
- investment;
- merger;
- acquisition;
- corporate reorganization;
- sale of assets;
- joint venture;
- bankruptcy;
- insolvency; or
- other corporate transaction.
Information may be disclosed to:
- prospective investors;
- purchasers;
- advisers;
- financing parties;
- affiliates; or
- transaction counterparties
where reasonably necessary and subject to applicable legal protections.
A successor entity may continue to process personal information in accordance with this Privacy Policy or another notice provided as required by law.
34. Legal Requests and Safety
Seeo may preserve, access, use, or disclose personal information where we reasonably believe doing so is necessary or appropriate to:
- comply with applicable law;
- respond to a valid court order;
- respond to lawful government or regulatory requests;
- enforce Seeo agreements;
- investigate fraud;
- investigate illegal conduct;
- investigate safety incidents;
- protect Seeo's legal rights;
- protect the rights of Hosts or Travelers;
- prevent serious harm;
- protect life or physical safety; or
- establish, exercise, or defend legal claims.
Where legally permitted and appropriate, Seeo may challenge or narrow requests that we believe are invalid, overly broad, or unlawful.
Nothing in this Privacy Policy requires Seeo to provide advance notice of a disclosure where notice is prohibited by law or would compromise a legitimate investigation or safety matter.
35. Changes to This Privacy Policy
Seeo may update this Privacy Policy from time to time to reflect changes in:
- Platform functionality;
- information practices;
- service providers;
- business operations;
- legal requirements;
- regulatory obligations;
- security practices; or
- other legitimate operational needs.
The current version will display its Last Updated date.
If changes are material, Seeo may provide notice through methods such as:
- email;
- Platform notification;
- account notice; or
- prominent notice on the Seeo Platform.
Where applicable law requires renewed or separate consent for a changed processing activity, Seeo will request such consent where required.
Changes to this Privacy Policy do not retroactively create consent for activities that legally require consent.
36. Contact Us
For questions, requests, or concerns regarding this Privacy Policy or Seeo's handling of personal information, contact:
China Unlocked Doing business as Seeo
Privacy Inquiries: support@seeotravel.com
Privacy Rights Requests: support@seeotravel.com
General Support: support@seeotravel.com
Where applicable law gives you the right to contact a privacy, data-protection, or consumer-protection authority, contacting Seeo first does not limit that right.