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Chapter 1. General Provisions
Article 1 (Purpose)
This Policy is established to define the standards for the
registration, operation, sale, customer service, settlement, and compliance
obligations of partners who sell travel products and related services through
ComboBooking.com and its related web and mobile services operated by Coach
Travel Co., Ltd. (hereinafter referred to as the “Company”), in order to
provide users with a reliable booking environment and to build a sound and
sustainable cooperative relationship between the Company and its partners.
This Policy is not intended merely to set standards for sales
restrictions or sanctions. It also includes operational standards designed to
enable partners to sell their products based on accurate information and stable
operations, while creating an environment in which users can make reservations
with confidence.
Through this Policy, the Company respects the autonomous sales
activities of its partners, while establishing the minimum management standards
necessary to protect users and ensure the reliability of the platform.
Article 2 (Scope of Application)
This Policy applies to all sales-related services operated or
provided by the Company, including but not limited to the ComboBooking.com
website, mobile services, affiliated channels, advertising pages, promotional
campaigns, blogs, review-linked pages, and any other sales-support services.
This Policy shall be applied in conjunction with the Partner
Agreement, Terms of Service for users, Refund Policy, Privacy Policy, Cookie
Policy, and policies related to electronic contracts and payment services. In
the event of any conflict, the provisions specified in individual agreements or
separate policies may take precedence.
If a partner registers, modifies, displays, or sells products
through the Company’s platform, or uses any sales support functions provided by
the Company, such partner shall be deemed to have agreed to and be bound by
this Policy.
Article 3 (Nature of the Platform)
The Company is an e-commerce intermediary that provides an
online platform enabling transactions of travel products and related services.
The Company may provide services such as product display,
booking processing, payment integration, advertising tools, customer
communication environments, and basic dispute resolution procedures. However,
the primary responsibility for the actual operation of individual
products—including on-site service delivery, schedule fulfillment, safety
management, facility conditions, personnel management, service quality,
regulatory compliance, and licensing requirements—rests with the partner who
registers and operates the relevant product.
Nevertheless, in order to protect users, comply with applicable
laws, maintain platform reliability, prevent misleading sales practices, and
mitigate recurring risks, the Company may take necessary measures such as
product review, requests for information correction, approval suspension,
display restriction, sales suspension, settlement withholding, or contract
termination.
As a platform operator, the Company endeavors to maintain
required disclosures, data protection, and consumer protection systems in
accordance with applicable laws. In Vietnam, the legal framework for e-commerce
and consumer protection addresses both platform operators and business
entities, making the clear distinction of roles between the platform and
selling partners particularly important.
Article 4 (Definitions)
The terms used in this Policy shall be defined as follows:
1. “Partner” refers to an
individual business operator, corporate entity, organization, or operator
approved by the Company who registers and sells products or services on the
Company’s platform.
2. “Product” refers to all
tangible and intangible services offered on the platform, including but not
limited to tours, activities, accommodations, transportation, pick-up services,
tickets, experiences, rentals, food and beverage services, packages, booking services,
or similar offerings.
3. “User” refers to any
individual or entity (including both members and non-members) who searches for,
books, pays for, uses, or inquires about products through the platform.
4. “Booking Request” refers to the
state in which a user expresses the intention to use a specific product and
proceeds with the booking process through the platform.
5. “Booking Confirmation” refers to the
state in which a partner approves the booking request and makes the product
available for actual use.
6. “Settlement” refers to the
process by which the Company pays the partner after deducting service fees,
discount contributions, advertising costs, refunds, and other applicable
deductions from the amount paid by the user.
7. “Content-linked
Product” refers to a product that is displayed or sold in
connection with blogs, travel stories, reviews, recommendation content,
promotional posts, or similar content.
8. “No-show” refers to a
situation where a user fails to appear at the scheduled usage time or meeting
time without prior cancellation, or does not meet the usage conditions as
defined for each product.
Chapter 2. Partner Registration and Basic Obligations
Article 5 (Partner
Registration and Eligibility Requirements)
Partners must complete the registration and review procedures
prescribed by the Company and must ensure that the following information is
accurate and kept up to date both at the time of registration and throughout
their operation:
1. Business name or
operating entity name
2. Name of the
representative or responsible person
3. Business registration
information or equivalent legal registration details
4. Contactable phone
number, email address, and emergency contact method
5. Business address or
actual operating location
6. Settlement account
information
7. Information required
for tax invoicing, remittance, or legal compliance
8. Licenses,
registrations, certifications, insurance coverage related to the business, and
supporting documentation
The Company may review the accuracy of registration information,
actual operational capability, legal compliance, and potential consumer
protection risks. If necessary, the Company may request additional
documentation, conduct interviews, require trial operations, request
explanations of operational methods, or verify the identity of responsible
personnel.
If a partner provides false information, fails to comply with
documentation requests without valid reason, conceals the actual operating
entity, or intentionally misrepresents the relationship between the registered
entity and the actual operator, the Company may take measures including
approval suspension, sales restriction, settlement withholding, or termination
of the agreement.
Article 6 (Basic Obligations of Partners)
When selling products through the platform, partners shall
faithfully fulfill the following basic obligations:
First, partners must ensure that the information of registered
products is always accurate and consistent with the actual services provided.
Second, partners must clearly and transparently disclose
pricing, options, usage conditions, inclusions, exclusions, and cancellation
and refund policies.
Third, partners must respond promptly and diligently to booking
requests, confirmations, schedule changes, cancellation requests, inquiries,
and customer complaints.
Fourth, partners must only sell products that can be actually
operated and must not accept or leave bookings unattended when the service
cannot be fulfilled.
Fifth, partners must comply with applicable laws and
regulations, including but not limited to tourism regulations, safety
standards, tax obligations, and personal data protection requirements.
Sixth, partners must cooperate with the Company by providing
requested materials, explanations, clarifications, and participating in
inspection or verification processes when required for user protection or
policy review.
Partners shall not register products solely for the purpose of
exposure or increasing sales visibility without actual service capability, and
must manage products based on real operational capacity and responsibility.
Article 7 (Obligation for Accuracy and Updates of Information)
Partners must provide registration information and product
information to the Company based on factual accuracy and shall promptly update
such information when any changes occur.
If any of the following changes arise, the partner must
immediately update the information through the Company or the partner
management interface:
1. Changes to the
representative or responsible operator
2. Changes to contact
information, email address, or settlement account
3. Changes to business
address or operating location
4. Changes to licensing or
regulatory status
5. Changes to service
conditions, schedules, pricing, or option structures
6. Suspension of
operations or planned business closure
If failure to update such information results in user damage,
booking errors, settlement errors, legal issues, or disputes, the Company may
hold the partner responsible.
Chapter 3. Product Registration and Sales Standards
Article 8 (Product
Registration Standards)
Partners must register products using the format provided by the
Company and must clearly provide at least the following information:
1. Product name
2. Product type and usage
format
3. Location of use,
region, and meeting point
4. Available dates and
times
5. Option structure and
pricing for each option
6. Inclusions and
exclusions
7. Booking deadline and
confirmation method
8. Voucher usage method or
on-site verification method
9. Cancellation,
modification, refund, and no-show policies
10. Usage restrictions, age
requirements, health conditions, and required preparations
11. On-site contact
information or emergency response method
12. Information on the
actual service provider or operating partner
The Company may suspend approval or request modifications if
required information is missing, if there is a risk of misleading users, or if
the registration format does not meet the Company’s standards.
Article 9 (Principles for Product Information)
When preparing product information, partners must comply with
the following principles:
Product descriptions must be based on the actual scope of
services provided and must not present benefits or options that are not
actually offered as if they were included.
Product images, videos, maps, itineraries, descriptions, and
highlighted statements must be consistent with the level of service that users
can reasonably expect.
If additional costs may be incurred by the user, the conditions
under which such costs arise and the amount or calculation method must be
clearly disclosed. Vague expressions such as “additional charges may apply
depending on on-site conditions” may not be permitted.
If availability is subject to factors such as seasonality,
weather, day of the week, minimum number of participants, or local operational
conditions, the partner must clearly and thoroughly disclose such conditions.
If product descriptions are deemed excessively exaggerated,
likely to cause misunderstanding, or significantly different from actual
operations, the Company may request modifications or restrict the product’s
visibility.
Article 10 (Pricing and Option Management)
Partners may autonomously set product pricing, options,
discounts, and promotional structures. However, the following standards must be
observed:
All prices must be displayed in a way that allows users to
clearly understand them at the time of payment. Differences between options,
pricing based on the number of participants, distinctions between adults,
children, and infants, date-based pricing variations, and peak season
surcharges must be clearly specified.
If there are additional costs beyond the base price—such as
taxes, service charges, equipment fees, pick-up fees, guide tips, entrance
fees, or on-site payments—such details must be disclosed in advance.
The following practices are prohibited: displaying excessive
discount rates based on unrealistic original prices, using bait pricing that is
practically unavailable for booking, or presenting condition-based pricing as
if it were a standard price.
For products with complex option structures, partners must
provide sufficient descriptions for each option to ensure that users are not
misled.
Article 11 (Standards for Content and Image Usage)
All images, descriptions, logos, videos, maps, itineraries, and
other materials uploaded by partners must be content for which the partner
holds lawful rights of use.
The unauthorized use of materials such as photos taken by
others, review content from other platforms, competitors’ product detail
images, improperly translated promotional materials, or copyrighted blog images
is strictly prohibited.
When quoting user reviews, testimonials, or blog content,
partners must verify the source and usage rights. Furthermore, partners must
not use reviews unrelated to the actual service in a way that may mislead
users.
If a rights infringement claim is filed or if the Company
reasonably determines that there is a high risk of infringement, the Company
may remove the relevant content or suspend the product’s visibility without
prior notice.
Chapter 4. Booking Confirmation and On-site Operation
Article 12 (Handling of
Booking Requests)
Partners must review and process booking requests received
through the platform within the timeframe specified by the Company, including
confirming or rejecting the booking.
For reservation-based products, the confirmation method may vary
depending on the nature of the product, such as instant confirmation, manual
confirmation, or confirmation upon request. However, partners must clearly
disclose the applicable confirmation method for each product.
If a partner fails to respond for an extended period, resulting
in unclear booking status, the Company may take necessary measures to protect
users, including canceling the booking, suggesting alternative products,
notifying the customer, or issuing a warning to the partner.
Article 13 (Obligations After Booking Confirmation)
After confirming a booking, partners must responsibly manage and
ensure the following:
1. The actual operability
of the scheduled service
2. The accuracy of the
meeting location, usage time, and voucher usage method
3. Proper reflection of
the user’s name, number of participants, and selected options
4. Information sharing
between the on-site service provider and responsible personnel
5. Readiness to ensure
that the user can access and use the service upon arrival
If the service becomes unavailable due to reasons attributable
to the partner after the booking has been confirmed, the Company may require
appropriate measures such as full refunds, alternative arrangements, or
compensation.
Article 14 (On-site Operation and Safety Management)
Partners, as the actual service providers, are responsible for
on-site operations and safety management.
On-site personnel—including guides, drivers, coordinators,
staff, and equipment managers—must possess the necessary experience and
qualifications to operate the product. Where legally required, partners must
maintain all relevant licenses and certifications.
All service components—including vehicles (cars, boats, etc.),
equipment, accommodations, restaurants, tickets, and facilities—must be in a
usable and operational condition. After booking confirmation, partners must not
substitute with lower-quality alternatives without justification.
For products involving safety risks, such as activities,
mountain or marine experiences, or transportation services, partners must
clearly inform users in advance of participation restrictions and safety
precautions.
In the event of emergencies such as accidents, injuries, loss,
schedule disruptions, on-site disputes, or failure to deliver services,
partners must take immediate on-site action, notify the Company, and
communicate promptly and responsibly with the user.
Article 15 (Operational Failure, Schedule Changes, and Force
Majeure)
If the operation of a product becomes difficult due to reasons
such as adverse weather conditions, natural disasters, government restrictions,
on-site facility issues, supplier constraints, failure to meet minimum
participant requirements, safety risks, or similar circumstances, the partner
must promptly notify both the Company and the user.
In such cases, the partner must provide the following
information:
1. The reason for the
operational failure or schedule change
2. Available alternative
schedules or substitute options
3. Refund eligibility and
applicable criteria
4. The scope of choices
available to the user
5. Any additional costs or
the expected timeline for refunds
Partners must not use such circumstances as a reason to
unilaterally cease communication with customers or leave bookings unattended
without proper notice.
Chapter 5. Customer Support, Cancellation, and Refunds
Article 16 (Customer
Support Standards)
Partners must respond promptly and in good faith to user
inquiries, including questions, change requests, cancellation requests, on-site
issue reports, and dispute requests.
As the nature of inquiries differs—such as pre-use inquiries,
urgent communications on the day of use, and post-use claims—partners must
establish appropriate response systems for each situation.
In particular, from 24 hours prior to the service date until the
end of the service, partners must maintain availability for urgent on-site
communication. To ensure this, partners must provide an active contact number
or messaging support system.
If the Company identifies delayed responses, repeated
non-responses, insincere communication, blaming customers, avoidance of
responsibility, or inaccurate information, the Company may request corrective
action or impose sanctions on the partner.
Article 17 (Cancellation, Change, and Refund Policy)
Partners must clearly disclose, in advance, the cancellation,
change, refund, and no-show policies for each product, and actual handling must
be consistent with those disclosed policies.
If a service cannot be provided due to reasons attributable to
the partner, a full refund shall be the default principle.
User cancellation requests must be processed in accordance with
the policies stated for the product. Partners must not arbitrarily change
cancellation policies after a booking has been confirmed, nor apply any
undisclosed deduction criteria.
When applying no-show policies, partners must do so fairly and
only if they have clearly informed users in advance of the meeting time,
waiting time, on-site contact procedures, and verification methods.
In cases of force majeure such as adverse weather, natural
disasters, or local restrictions, handling may follow product-specific policies
and applicable laws. However, partners are obligated to clearly explain the
reasons and handling principles to users.
Article 18 (Unfair Refund Refusal and Repeated Claims)
Partners must not intentionally delay or refuse refunds when
there are valid grounds for refund.
The Company may consider the following cases as improper
handling:
1. When an issue
attributable to the partner is falsely treated as a user’s fault
2. When deductions are
applied without prior disclosure
3. When refund processing
is delayed due to avoidance of user inquiries
4. When similar types of
disputes occur repeatedly
5. When operations differ
from the registered refund policy
In cases of repeated arbitrary cancellations, unfair refund
refusals, excessive misuse of no-show policies, or repeated occurrence of
similar disputes, the Company may take actions such as suspension of product
sales, restriction on new product registration, limitation of advertising, or
withholding of settlement payments.
Chapter 6. Content-Linked Operations and Trust Management
Article 19 (Special
Standards for Content-Linked Products)
Products linked to blogs, travel stories, recommendation
content, reviews, promotional posts, or similar content are subject to higher
standards of accuracy and reliability than general products.
If key elements emphasized in the content—such as core
experiences, locations, itineraries, inclusions, atmosphere, transportation,
accommodation standards, or benefits—differ significantly from the actual
product, it may be considered misleading to users.
If the content presented does not substantially match the actual
product being sold, the partner must clearly explain the differences. The
Company may conduct additional reviews, request modifications, restrict content
visibility, or suspend product sales.
As products driven by content-based traffic are directly linked
to platform trust, the Company may prioritize the review and monitoring of such
products over general listings.
Article 20 (Reviews and Trust Management)
Partners must not artificially intervene in or manipulate user
reviews, ratings, feedback, or satisfaction metrics.
The following actions are strictly prohibited: posting fake
reviews, submitting self-reviews through acquaintances or employees, defaming
competitors, forcing users to delete reviews, or offering incentives in
exchange for reviews.
The Company may evaluate product quality based on factors such
as repeated low ratings, recurring types of complaints, or discrepancies
between reviews and product descriptions. Based on the evaluation results, the
Company may request improvements or impose visibility restrictions.
Chapter 7. Personal Data Protection and Legal Compliance
Article 21
(Restrictions on the Use of User Information)
Partners may use user information only to the extent necessary
for processing bookings and providing actual services.
User information must be used solely for legitimate purposes
such as booking confirmation, on-site operations, schedule change
notifications, refund processing, emergency contact, and ensuring user safety.
It must not be used beyond these purposes for independent marketing, external
business activities, resale, unauthorized storage, or unauthorized sharing.
Vietnam’s personal data protection regulations are currently
governed by Decree No. 13/2023/ND-CP (2023), which establishes requirements on
purpose limitation, data subject rights, processing conditions, and security
measures.
Article 22 (Personal Data Protection Measures)
Partners must implement necessary technical and administrative
measures to prevent the loss, theft, leakage, alteration, or damage of user
personal data.
Access to personal data must be restricted to the minimum extent
necessary. Once the purpose of processing has been fulfilled, the data must be
promptly deleted or destroyed unless retention is required by law.
If a partner provides user information to third parties without
authorization, or uses it for external promotion, independent business
activities, spam distribution, building separate databases, or personal
contact, the Company may consider this a serious violation of the policy.
Article 23 (Compliance with Applicable Laws)
Partners must comply with all applicable laws and regulations
related to the sale and operation of products, including but not limited to
those concerning tourism, accommodation, transportation, activities, safety,
taxation, advertising, consumer protection, and personal data protection.
With respect to consumer protection, Vietnam’s Law on Protection
of Consumer Rights (2023) came into effect on July 1, 2024, strengthening the
obligations of businesses to provide accurate information and enhancing the
protection of consumer rights.
Chapter 8. Prohibited Activities and Sanctions
Article 24 (Prohibited
Activities)
Partners must not engage in any of the following activities:
1. Registering false
products, displaying inaccurate schedules, or misrepresenting inventory
availability
2. Selling products that
cannot be actually operated or delivered
3. Selling unauthorized or
illegal products
4. Inducing users to make
payments outside the platform or engage in direct transactions
5. Creating fake reviews,
self-transactions, fake bookings, or manipulating rankings
6. Using others’ photos,
videos, trademarks, reviews, or descriptions without authorization
7. Collecting, using, or
sharing user personal data without authorization
8. Inserting misleading or
irrelevant keywords to manipulate search exposure
9. Impersonating or
causing confusion with the Company or other partners
10. Engaging in activities
that harm user safety or undermine platform trust
11. Violating applicable
laws, public order and morals, or Company policies
Điều 25 (Hạn chế bán hàng và biện pháp xử lý)
Trong trường hợp đối tác vi phạm chính sách này hoặc các quy
định pháp luật liên quan, Công ty có thể áp dụng các biện pháp sau đây tùy theo
mức độ vi phạm, tính lặp lại, quy mô thiệt hại đối với người tiêu dùng và mức
độ cố ý:
1. Thông báo hoặc yêu cầu
chỉnh sửa
2. Cảnh báo
3. Tạm hoãn phê duyệt sản
phẩm
4. Hạn chế hiển thị sản
phẩm
5. Tạm ngừng bán đối với
sản phẩm cụ thể
6. Hạn chế đăng sản phẩm
mới
7. Hạn chế sử dụng dịch vụ
quảng cáo
8. Tạm hoãn thanh toán
9. Chấm dứt hợp đồng và
hạn chế đăng ký lại
Trong trường hợp có thể, Công ty sẽ thông báo trước và tạo cơ
hội để đối tác giải trình. Tuy nhiên, trong các trường hợp cần ngăn chặn thiệt
hại cho người tiêu dùng, xử lý khẩn cấp về an toàn hoặc ngăn chặn hành vi vi
phạm pháp luật rõ ràng, Công ty có thể thực hiện biện pháp xử lý trước và thông
báo sau.
Article 26 (Management of Repeated Violations)
If the same or similar types of violations occur two or more
times within the most recent three-month period, the Company may impose
stricter sanctions than those applied to general violations.
Examples of repeated violations include:
1. Repeated disputes of
the same type regarding refunds
2. Repeated failure to
respond to booking requests
3. Repeated operation of
inaccurate or false schedules
4. Repeated customer
dissatisfaction or poor on-site operations
5. Repeated misuse of
personal data
6. Repeated inducement of
off-platform direct transactions
Chapter 9. Settlement and Contract Termination
Article 27 (Settlement
Principles)
Payments to partners are calculated after deducting platform
fees, advertising costs, partner-borne discount contributions, refunds, card or
payment-related deductions, and other agreed costs from the amount paid by
users.
The specific settlement cycle, tax handling method, payment
date, payment currency, and deduction items shall follow the Company’s
settlement policy or individual agreements.
Partners must ensure that all settlement-related information,
including tax documents, bank account details, and remittance information, is
accurate and kept up to date.
Article 28 (Grounds for Withholding Settlement)
The Company may withhold part or all of the settlement amount in
the following cases:
1. When there are pending
refunds
2. When payment
withholding is requested by a card issuer or payment provider
3. When fraudulent or
suspicious transactions are suspected
4. When customer disputes
or legal disputes are ongoing
5. When the partner fails
to provide requested supporting documents
6. When there is a risk of
consumer harm or escalation of damages
7. When there is a request
from a court, regulatory authority, or competent authority
The Company may resume settlement once the reasons for
withholding have been resolved, in accordance with the relevant criteria.
Article 29 (Termination and Post-Termination Responsibilities)
Partners may notify the Company of their intention to terminate
the agreement at any time. However, they must fulfill all obligations related
to ongoing bookings, refunds, customer support, dispute handling, taxation, and
settlement.
Even if the Company terminates the agreement, the partner shall
not be exempt from responsibilities arising from products sold prior to
termination.
After termination, provisions relating to personal data
protection, confidentiality, settlement and refunds, liability for damages,
intellectual property responsibilities, and user claim handling shall remain in
effect to the extent required by their nature.
Article 30 (Indemnification)
If any damage is caused to users, the Company, or third parties
due to reasons attributable to the partner, the partner shall be liable for
such damages.
If the Company incurs costs such as refunds, compensation,
administrative actions, legal proceedings, dispute resolution, or reputation
recovery due to the partner’s actions—including false information registration,
illegal sales, safety incidents, copyright infringement, personal data
breaches, unfair refusal of refunds, or failure to provide on-site services—the
Company may claim reimbursement of such costs from the partner.
Chapter 10. Miscellaneous
Article 31 (Confidentiality)
The Company and the partner shall not disclose to any third
party or use for purposes other than the implementation of this policy any
confidential business, technical, customer service, or settlement-related
information obtained during the course of the agreement and operations, without
the consent of the other party.
This provision shall remain in effect even after termination of
the agreement.
Article 32 (Amendments to the Policy)
The Company may amend this policy in accordance with changes in
applicable laws, service structure, operational policies, or platform
functionalities.
In the event of significant changes, the Company will provide
prior notice before the effective date through appropriate channels such as
platform notices, email, partner management pages, or other suitable means.
Article 33 (Governing Law and Dispute Resolution)
This policy shall be governed by and interpreted in accordance
with the laws of Vietnam.
In the event of a dispute between the Company and the partner in
connection with this policy, the parties shall first attempt to resolve the
matter through good-faith negotiations. If no agreement is reached, the dispute
shall be resolved by the competent court having jurisdiction over the Company’s
principal place of business or in accordance with applicable laws.