WHAT THE POLICIES SAY

Trip.com is a Chinese-founded, globally operating online travel platform (formerly Ctrip) owned by Nasdaq/HKEX-listed Trip.com Group Limited, a Cayman Islands holding company headquartered in Singapore that consolidates its PRC operations through a variable-interest-entity (VIE) structure. Its consumer privacy notice discloses routine collection of passport numbers, national ID numbers, dates of birth and nationality for bookings, cross-device cookie-based ad tracking with third parties, and a self-declared "sell"/"share" of personal data for targeted advertising with an opt-out. The company's FY2025 Form 20-F (filed with the SEC) discloses that PRC data-protection law bars entities within PRC territory from providing data to foreign judicial or law-enforcement bodies without PRC government approval — a state-access framework layered on top of the routine ad-sharing. The same filing states no material cybersecurity incident occurred in 2023-2025, while separately disclosing an unrelated, ongoing PRC antitrust (SAMR) investigation opened in January 2026 and a US securities class action opened in March 2026; neither is privacy-specific.

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[2026-06-05] · COLLECTION

Trip.com's privacy notice (last updated 2026-06-05) states that for flight ticket bookings it collects date of birth, nationality, gender, passport number, passport expiration date, passport photo and Known Traveler Number, with similar government-ID fields (ID number, expiration date) collected for train tickets in mainland China and passport data for hotel, bus/cruise and e-visa bookings.

us.trip.com ↗

[2026-04-28] · OWNERSHIP TRANSPARENCY

Trip.com Group Limited's FY2025 Form 20-F identifies the registrant as a Cayman Islands-incorporated company headquartered in Singapore, and discloses that its PRC operations are consolidated not through direct equity ownership but through variable interest entities (VIEs) -- companies incorporated in China that are bound to the group by a series of contractual arrangements with PRC subsidiaries rather than by share ownership.

sec.gov ↗

[2026-04-28] · SHARING

Trip.com Group Limited's FY2025 Form 20-F (filed with the SEC) discloses as a risk factor that the PRC Data Security Law and PRC Personal Information Protection Law provide that no entity or individual within PRC territory may provide data or personal information stored within PRC territory to any foreign judicial or law-enforcement body without approval from the competent PRC government authority.

sec.gov ↗

[2026-06-05] · SHARING

Trip.com's privacy notice states that some laws define "sell" and "share" broadly enough that some of its described data sharing may be considered a sale or sharing under those definitions, and offers a "Do Not Sell or Share My Personal Information" opt-out alongside support for the Global Privacy Control signal.

us.trip.com ↗

[2026-04-28] · TRACK RECORD

Trip.com Group Limited's FY2025 Form 20-F states in its Cybersecurity item that the company did not experience any material cybersecurity incident in 2023, 2024, or 2025 through the date of the annual report, while its Legal Proceedings section separately discloses an ongoing PRC SAMR antitrust investigation opened January 2026 and a US securities class action filed March 2026, neither of which is privacy-related.

sec.gov ↗

TRACKING TECH

The Trip.com iOS App Store listing's developer-declared App Privacy section states that Location, Contact Info and Identifiers may be used to track the user across apps and websites owned by other companies, and separately lists Contact Info among data linked to identity for Third-Party Advertising.

apps.apple.com ↗

[2026-06-05] · TRACKING TECH

Trip.com's privacy notice states that its marketing activities involve cross-device tracking, where third parties collect information about the user's online activities via cookies across multiple linked devices and combine it to tailor advertisements shown across the internet to the user's interests, referring users to a separate Cookie Statement for detail.

us.trip.com ↗

LAST REVIEWED 2026-08-19 · METHODOLOGY v1.7