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CMV Privacy Policy

The Company and personal information

Cruise & Maritime Voyages Ltd are part of the CMV Holdings London Travel & Leisure Group. We collect and process data about enquirers and guests to promote, deliver and improve our services. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information are carried out in accordance with applicable data protection laws. The main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.

What this privacy notice is

This privacy notice sets out the basis on which we will process any personal information about you or individuals generally - whether it’s personal data we collect from those individuals or that is provided to us from other sources. This privacy notice sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal data.

Why you should read this privacy notice

It is important that you read this privacy notice, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.

Some basic definitions we use in this privacy notice

Personal Data: In this privacy notice, when we use the term “personal data” we mean any information relating to an identified or identifiable living human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).

Sensitive personal data: In this privacy notice, when we use the term “sensitive personal data” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning a someone’s sex life or sexual orientation.

Why we process your personal data

We process personal data about enquirers and guests before, during and after their cruises to support our customers and our business interests, which include:

  • Making enquirers and guests aware of news and offers from Cruise & Maritime Voyages Ltd
  • Providing services to our guests and documenting what services we have provided
  • Managing the health, welfare, safety, and security of our guests
  • Handling enquiries, complaints, and investigations
  • Operating Columbus Club loyalty programmes
  • Monitoring and improving the quality of our training and services
  • Researching and understanding your preferences and needs to improve our marketing effectiveness
  • Working with our partners such as onboard boutiques, casino, photo gallery and spas to manage billing and improve the quality of their services

We also process personal data about job applicants, current and former employees, service providers, travel agents and other groups of individuals during employment and business operations, and this data is subject to our internal privacy policies.

What personal data we collect

We collect your personal data when you enquire, book, sail, or communicate with us. Below are examples of the data we collect when you communicate with us.

  • Enquiry: Personal details such as name, gender, age etc. Contact information such as home address, phone number, email address, holiday preferences
  • Booking: Personal details, contact information, booking preferences, financial details (credit/debit card, bank details), travel documents (passport number), care needs (medical, dietary, mobility etc.), dining preferences, other travel details (vehicle registration, excursion bookings)
  • Onboard Activity: Financial details, bookings, and billing for onboard services and shore excursions photographs taken during the cruise
  • Enquiries & Complaints: Personal details, contact information, enquiry or complaint details
  • Loyalty Programme: Personal details, contact information, communications preferences, cruise history
  • Health & Medical: Medical, dietary and mobility details provided to us before, during or after the cruise
  • Security & Safety: Travel documents, facial photography, incident reports or witness statements
  • Surveys & Market Research: Responses to post-cruise surveys
  • Additional Services: If you purchase services, a gift or surprise booking, we will record your details as needed in relation to the individual(s) for whom the gift or surprise booking was purchased.

Personal data generated by your interactions with us

Your interactions with us will result in personal data being created and stored by us. Examples include:

  • Booking: Booking party details, reference numbers, travel itineraries, flight bookings, manifests, immigration details;
  • Onboard Activity: On-board spending, boutique spending, casino spending, spa/gym specialist interactions, dining records;
  • Enquiries & Complaints: Enquiries or complaints and associated investigation and correspondence before, during or after a cruise;
  • Loyalty Programme: Nights on board, cumulative spending;
  • Health & Welfare: Medical reports, billing data, welfare reports, correspondence;
  • Security & Safety: Accident/incident reports, witness statements, embarkation/disembarkation logs, CCTV recordings, police reports.

Personal data we create

We analyse the personal data we hold to improve the effectiveness of our direct marketing communications or to deliver our loyalty programmes. This can, in turn, generate personal data; for example, helping us to decide which marketing communications are likely to be of interest to you or to determine your loyalty status.

Personal data from other organisations

We receive personal data from other individuals or third-party organisations. For example, when making a booking we will receive details of all members of the booking party from the guest making the booking. We may receive personal data from third-party organisations including travel agents processing bookings on a guest’s behalf, from competitions or promotions where personal data has been provided as part of the competition or promotion, or from social media where personal data has been posted on our social media pages. We use publicly accessible data sources such as data brokers to maintain the accuracy of our enquirer and guest records and may from time to time use external sources to help us to resolve disputes or recover unpaid accounts.

Sensitive personal data

Processing of sensitive personal information requires higher levels of protection. We do not process sensitive personal data about you except where there is a legal reason to do so. For example, we will process information about an individual’s physical or mental health, or disability status, to ensure health and safety and to provide appropriate adjustments the individual might require to access the services we have arranged for the individual. Sensitive personal data can include:

  • Health: We collect personal data about guest health as part of the booking and embarkation processes, or where guests use medical services on board ship. This may be retained for subsequent care purposes and to facilitate billing for services provided.
  • Biometrics: We use photographs of our guests to maintain security and safety whilst they are on board our ships. These are not retained or used for other purposes.
  • Sexual orientation: Enquirers and guests may from time to time choose to provide data to us relating to their sexual orientation or gender identity so that we can maintain their health, welfare, and enjoyment of the services we provide (though we will not actively seek to collect such information).

We process personal data about children to provide services when they are guests on our ships. We do not collect personal data about children for any other purpose.

We may from time to time be asked to process personal data relating to the criminal history of individuals, for example, if we receive a request from law enforcement authorities, or when investigating security matters that might involve law enforcement.

How we process personal data

We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the personal data about you.

We will only process personal data when the law allows us to do so and relying on a relevant basis for lawful processing indicated below in each instance:

  • Where we need to perform a contract we are about to enter into or have entered in to with you
  • Where we need to comply with a legal or regulatory obligation
  • Where it is necessary to protect your vital interests or the vital interests of those around you
  • Where it is necessary for our legitimate interests or (those of a third party), and we have undertaken an assessment to determine that processing for those interests does not override your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place
  • Where you have consented to the processing

In this Privacy Notice, where we need your consent, we will make sure that that consent:

  • is specific consent for one or more specified purposes; and
  • is given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of your agreement to the relevant processing of personal information.

We will only use personal data about you for the purpose it was collected for or closely related purposes and will inform you or seek your consent if we need to use it for other purposes.

Enquiries

If you enquire about our products or engage in competitions or other promotional activities that we provide, we may ask your consent to provide you with news and offers about our services that you may find of interest. Depending on your preferences, our communications with you may include:

  • By Email - We monitor our email communications, including where emails are undelivered and whether or not they appear to have been read. We may cease sending you email communications should we be unable to deliver email to you.
  • By Post - We may from time to time send postal communications including brochures, newsletters, and offers. Where letters are returned to us, or where external data providers notify us of changes, we take steps to update our records. We may cease sending you postal communications if we believe we are no longer able to contact you at the address on file.
  • Calls - Calls made to us, and calls received from us may be recorded for the purposes of training and the monitoring of services provided by us.
  • Web - Visitors to our website may be tracked using analytics methods described in our Cookies Policy which can be viewed on our website at https://www.cruiseandmaritime.com/main/cookie-policy

You may withdraw or amend your consent to receive news and offers at any time.

Bookings

When you make a booking either directly or through a travel agent, we will collect personal data about you and other travellers in your group, including your names, genders, dates of birth, home addresses, phone, email, details of any medical, care or dietary requirements, specific preferences relating to the booking you have selected, and your payment details. We need this data to enter into a contract with you.

If you provide us with personal data about any other individuals included in a booking, you must have the authority of those individuals to provide their personal data to us for the purposes set out in this Privacy Notice and will remain accountable for the information provided. It is the responsibility of the booking leader to ensure that personal data about the group members is accurate and up to date.

Managing My Cruise

After you book a cruise, you can access our online Manage My Cruise service via our website to provide additional personal data about you and your travel party. This additional mandatory personal data including passport, insurance and emergency contact details for you and your booking group is necessary to complete your booking.

You may optionally book or purchase on-board products and services, excursions and other activities, which may require you to provide further personal data. We may have to share your personal data with other companies such as spa operators, shore excursion agents or travel operators to provide these services.

Manage My Cruise contains data about a group of individuals in a booking, including personal data, outstanding balance, additional purchases such as gift packs and shore excursions. To improve security, we do not display sensitive personal information after it has been in entered in to the system.

Safety & Security

We will use personal data about you for the purposes of carrying out security checks. Personal data about you may be shared with recognised law enforcement agencies prior to boarding, during your cruise, or after disembarkation, for security and immigration purposes. Personal data may also be shared with these agencies in order to prevent and detect crime as well as to safeguard children and vulnerable adults. These checks may involve sending personal data between different countries, including countries outside the European Union.

For the safety and security of each ship and its passengers, and to maintain health and safety, we operate closed circuit television (CCTV) cameras on board our ships, including at all access points and throughout the public areas. These are recording continually with footage being retained and stored for a set period. Images taken from these cameras may be used internally for identification purposes and to assist with the investigation of safety or security related matters. Images may also be shared with law enforcement agencies (in any jurisdiction) in order to detect or prevent criminal activity or to assist in the apprehension and prosecution of offenders.

Health & Welfare

In the unlikely event that you are involved in an accident or require medical treatment on our ships, we may use personal data already provided to us, or obtained from you, to deliver your treatment. We may share that personal data with third-party healthcare providers with your consent or where it is in your vital interests or the public interest to do so, and retain a record of treatment provided for billing and obligatory record-keeping purposes.

Passenger Questionnaires

Before the end of your cruise, we will provide you with a questionnaire to seek feedback on your experience to understand your satisfaction level so that we can improve the quality of services we offer, and to assess the performance of our onboard staff and their associated rewards.

Columbus Club Loyalty Programme

We operate loyalty programmes that allow you to benefit from your time spent on our ships, through future offers that may include discounts, upgrades, early booking, competitions, gifts and other rewards. For this reason, we retain a basic record of cruises you have taken including your name, contact details, cruise numbers, dates, and any loyalty offers that you have redeemed with us. If you believe we hold incorrect historical cruise details, you can contact us with evidence of those cruises to correct your record.

We will contact you with details of our loyalty programme when you book your first cruise, and if you join you will receive further communications thereafter including details of your loyalty status and subsequent benefits You may opt out of the loyalty programme and programme-related communications at any time.

Sharing personal data

We process personal data about enquirers and guests in the UK and onboard our ships worldwide. We contract other companies and individuals to perform certain activities on our behalf, such as;

  • Fulfilling requests for brochures and promotional materials: printers, fulfillment service providers
  • Processing payments: banks, payment service providers;
  • Sending postal mail and e-mail communications: postal services, couriers, e-mail service providers;
  • Maintaining guest records and analysing data: customer insight agencies, credit agencies;
  • Providing port services and excursions:
  • Providing travel services: airlines, coach operators, travel agents.

These contractors have access to personal information needed to perform their functions but are not permitted to use it for other purposes.

If you make a booking we may pass your personal information on to other relevant suppliers of your travel arrangements such as airlines, hotels and transport companies. Your personal information may also be passed to travel agents, security and credit checking companies, credit and charge card companies. We are required to co-operate with government and law enforcement agencies and the public authorities of any country in your itinerary, including customs and immigration authorities.

We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also share personal information we hold with selected third party service providers to process your personal data. If we use a third-party data processor to process personal data on our behalf, we will obtain contractual commitments to safeguard the security of the personal data to ensure that the third party only acts on our instructions when using that personal data and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information.

Transferring personal data to third countries

We collect and process personal data in the European Union (EU). We may need to process your personal data worldwide, including onboard our ships, depending upon the destinations you travel to with us, for example, if we have to provide personal data to immigration authorities, port agents or excursion operators in destination countries. We will only transfer certain personal data that we hold to a country outside the EU if one of the following conditions applies:

  • The country to which the personal data is transferred ensures an adequate level of protection for that individual’s rights and freedoms;
  • Individuals have given their explicit and informed consent having had the risks explained to them;
  • The transfer is covered by one of the derogations set out in the GDPR, including the performance of a contract between us and that individual, or to protect the vital interests of individuals;
  • The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
  • The transfer is authorised by the relevant data protection authority where we have checked adequate safeguards exist with respect to the protection of the individual’s privacy, their fundamental rights and freedoms, and the exercise of their rights.

From time to time personal data may need to be shared with other parts of the CMV travel & Leisure Group outside of the EU to provide the services you request from us. We use legal mechanisms (‘binding corporate rules’), technical and procedural controls to safeguard your personal data in these circumstances.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision relevant to you without human intervention. We do not envisage that any decisions will be taken about you using automated means, however, we will notify you in writing if this position changes.

Direct Marketing

As indicated above, we may use your personal data to provide you with information about goods and services which may be of interest to you and we may contact you about these by post, email or telephone. This is known as direct marketing.

Examples of direct marketing may include:

  • Sending promotional emails about new products, special offers or other information which we think you may find useful or interesting using the email address which you have provided;
  • Contact you for market research purposes (by email, phone, or mail).

We will only process personal data for the above purposes with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.

We may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries) for the purpose of direct marketing. Again, we will only do this with your explicit consent. Again, you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.

Notices of your rights concerning your personal data

You have rights over how we use your personal data and can exercise those rights by contacting our Data Protection Officer, Cruise & Maritime Voyages Ltd, Gateway House, Stonehouse Lane, Purfleet, Essex RM19 1NS, or email privacy@cruiseandmaritime.com.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Withdrawing consent to the processing

Where we have obtained your consent for the processing of personal data about you, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Where we process personal data about you in ways for which your consent is not required, for example, to record your cruise history, you may ask us to cease processing, or restrict the nature of the processing, if you wish.

Accessing the personal data we hold about you

You may request a copy of the personal data we hold about you. This includes obtaining personal data about you in electronic form to provide to a third party should you wish to do so. Note that the right to request the transfer of your personal data to you or to a third party only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format.

Ensuring the accuracy of personal data we hold about you

We will update or amend personal data we hold about you if you inform us of inaccuracies. We use publicly accessible data sources such as data brokers to maintain the accuracy of data.

Deleting personal data we hold about you

We retain personal data for the period required for processing, and where we are under a legal obligation to do so, for example, billing data is retained in accordance with anti-money laundering and financial records keeping requirements.

We hold a basic record of guests’ cruise history (name and contact details, booking/cruise number, nights onboard) indefinitely for the purpose of maintaining our loyalty scheme.

We will delete personal data we hold about you if you ask us to do so, except where there is a good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objecting to the processing of your personal data

Where we are relying on a legitimate interest (of our own or of a third party) and if there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

Requesting restriction of processing of your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

How to complain about our processing of personal data

If you have a concern or complaint about our processing of personal data, please contact our Data Protection Officer by post at Data Protection Officer, Cruise & Maritime Voyages Ltd, Gateway House, Stonehouse Lane, Purfleet, Essex RM19 1NS, or email privacy@cruiseandmaritime.com.

If you are not satisfied with our processing of personal data, how we have responded to your complaint about the processing of personal data, or you believe our processing of personal data is not in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO) by calling +44 (0) 303 123 1113, or by visiting https://ico.org.uk/concerns/

We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.

Securing your personal data

We take the security of your personal data seriously and use security policies, standards, technologies and ongoing training to safeguard the personal data we process from improper access, use, alteration, destruction, and loss.

Where we share your personal data with other companies as described above, we require those companies to process your personal data to an equivalent level of security.

Data retention

We will not keep personal data in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will only keep personal data for as long as is necessary for the purpose or purposes for which that personal data is processed, and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.

We may sometimes anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Websites

Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.

Cookies

We use cookies and similar tools on our website to improve its performance and enhance your user experience. You can find out more about how we use cookies here https://www.cruiseandmaritime.com/main/cookie-policy

Contacting Us

Cruise & Maritime Voyages Ltd is part of the CMV Holdings London Travel & Leisure Group.
Cruise & Maritime Voyages Limited is a company registered in England and Wales. Registered number: 07665897 and is registered as a data controller with the Information Commissioner’s Office, registration number Z3193924.

All enquiries relating to data protection, including communications with our Data Protection Officer, should be sent to the Data Protection Officer, Cruise & Maritime Voyages Ltd, Gateway House, Stonehouse Lane, Purfleet, Essex RM19 1NS, or email privacy@cruiseandmaritime.com.

Changes to this privacy notice

This privacy notice was updated on [6th June 2018] and is reviewed at least annually. We reserve the right to change this privacy notice at any time. Where appropriate, we will notify individuals of those changes by mail or email.

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